Robb Chase is a member of Sutherland's Tax Practice Group and focuses his practice on domestic and international tax planning and the taxation of financial products. In the area of tax planning, Robb has extensive experience analyzing issues relating to acquisitions, dispositions, joint ventures, restructurings and finance company arrangements. He has counseled multi-national corporations in all aspects of structuring, negotiating, documenting and reporting cross-border transactions. Robb also has experience representing taxpayers in complex tax audit and litigation matters. Robb regularly advises clients on tax issues relating to domestic and foreign public and private debt offerings, synthetic and hybrid instruments, foreign currency transactions, swaps and derivatives, hedging transactions, and other complex financial products and transactions. He routinely counsels clients on the tax implications of modifications to, and defeasances of, commercial mortgages held by Real Estate Mortgage Investment Conduits (REMICs), as well as other aspects of the tax rules applicable to REMICs. Representative Experience Robb's recent representative experience includes: · Representing Tyco Electronics as tax counsel in its $1.25 billion acquisition of ADC. · Representing Kraft Foods Inc. as tax counsel in its purchase of Group Danone's global biscuit business for approximately $7.6 billion. · Acting as tax counsel to Philip Morris International Inc. in its acquisition of an increased stake in its Mexican tobacco business for approximately $1.1 billion. · Providing tax advice to Tyco Electronics regarding the consequences to it and its shareholders of the proposed change in its jurisdiction of incorporation. · Representing Philip Morris International Inc. following its spin-off from Altria on tax considerations relating to its tax-free debt and commercial paper programs. · Advising Philip Morris International Inc. on the tax aspects of its acquisition of a 100% interest in Industria de Tabaco León Jimenes, S.A. in exchange for its interest in E. León Jimenes, C. por. A., the Dominican beer, cigarette and cigar joint venture. · Advising Philip Morris International Inc. on the tax aspects of its acquisition of 97.95% of the shares of PT HM Sampoerna Tbk, an Indonesian kretek cigarette manufacturer. · As a member of the Mortgage Bankers Association's REMIC Working Group, providing industry comments and proposals to the Internal Revenue Service (IRS), which it used in drafting recently proposed modifications to the REMIC regulations. Professional Honors and Awards · Named among Washington, D.C.'s "40 Under 40" by Legal Times magazine (2009) · Recognized by The Legal 500 United States in the area of tax: international (2011) Professional and Community Involvement · Member, American Bar Association · Member, District of Columbia Bar Recent Publications and Speaking Engagements · Co-author, "Economic Substance Directive: Some Substance, Many Questions," State Tax Notes (August 22, 2011) · Co-author, "The FBAR Reset: Final Regulations Provide Mixed Guidance," Tax Notes (April 25, 2011) · Author, "Prevention of Mismatching of Interest and OID Deductions and Income Inclusions in Transactions with Related Foreign Persons" in "Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 P.L. 108-357," Vol. 45, No. 25, Tax Management Memorandum 563 (2004) · Author, "Proposed Contingent Notional Principal Contract Regulations (Warning: Don't Try This at Home)," Vol. 17, No. 5, Journal of Taxation and Regulation of Financial Institutions 36 (2004) · Co-author, "Regulations Proposed to Nullify Certain 'Disregarded Entity' Elections," Vol. 29, No. 3, Tax Management International Journal 131 (2000) · Co-author, "The Administration's Corporate Tax Shelter Proposals: What are the Limits of Appropriate Tax Planning?" Vol. 40, No.7, Tax Management Memorandum S-99 (1999) · Note, "Rate Review: Applying Chevron Deference to FERC Determination of its Jurisdiction" 64 George Washington Law Review 1195 (1996) · Speaker, "It's All in the Family: Federal Tax Considerations in Intragroup Restructurings," Tax Executives Institute: 62nd Midyear Conference (March 25, 2012) · Speaker, "Head in the Cloud: Applying Permanent Establishment, Nexus and Treaty Principles to Electronic Commerce Transactions," "International Tax Reform: Proposals and Prospects" and "What the FFI? The Non-Financial Institution's Guide to FBAR, FATCA and the Tax Implications of Dodd-Frank," TEI New Orleans: International Tax Developments Day (February 1, 2012) · Speaker, "Tax Reform Proposals and the Upcoming Regulatory Agenda," Sutherland Tax Series: Session II (December 6, 2011) · Speaker, "M&A Due Diligence," TEI Annual Conference (October 30-November 2, 2011) · Speaker, "State Tax Consequences of Federal Uncertain Tax Positions," TEI Seattle Chapter Meeting (September 26, 2011) · Speaker, "Tax Research," Sutherland Tax SABLE (July 13, 2011) · Speaker, "TerraLex Annual Meeting" (June 3, 2011) · Speaker, "Economic Substance and Reportable Transactions," TEI Seattle Chapter State and Local Tax Update (February 9, 2011) · Speaker, Tax Executives Institute (TEI) European Chapter Winter Conference (January 28-29, 2008) · Speaker, "Tax Aspects of Financing U.S. Operations," Council for International Tax Education (CITE) 9th Annual Conference on U.S. Inbound and Withholding Tax Update (April 23, 2007) News Sutherland Makes Mark in The Legal 500 for 2011
December 1, 2011 Sutherland Represents Tyco Electronics in its Acquisition of ADC
July 14, 2010 Robert S. Chase II Named Chair of Sutherland's Washington, D.C. Hiring Committee
August 25, 2009 The National Law Journal's LegalTimes' "40 Under 40" Recognizes Robert S. Chase II
July 13, 2009 Sutherland Represents Tyco Electronics Ltd. in $675 Million Sale of Its Wireless Systems Business to Harris Corporation
April 28, 2009 Legal Alerts Legal Alert: Regulatory Watch List for 2012: The Shifting Landscape for Hedge Funds and Other Private Funds
February 8, 2012 Legal Alert: Getting Specific: IRS Issues Guidance on Withholding for Specified Notional Principal Contracts Under Section 871(m), Delays Statutory Effective Date
January 27, 2012 Legal Alert: Assignment of the Times: New Tax Rules Respond to Concerns Regarding Assignment of Derivative Contracts Required by Dodd-Frank
July 25, 2011 Legal Alert: LB&I Internal Directive Limits Application of the Economic Substance Doctrine and Related Penalties, but Raises Concerns about Transparency and Consistency of Process
July 21, 2011 Legal Alert: It's Just a Phase: The "Phased Implementation" of FATCA Under Notice 2011-53
July 18, 2011 Legal Alert: Last Minute FBAR Extensions for "Signature Authority Only" Filers - Making Sense of the Announcements
June 21, 2011 Legal Alert: FinCEN Extends FBAR Filing Deadline for Certain Officers and Employees - Does This Portend Changes?
June 3, 2011 Legal Alert: Repeal of Expanded Form 1099 Reporting Requirements Signed into Law
April 18, 2011 Legal Alert: Spring Is in the Air, and So Is FATCA! Notice 2011-34 Offers Another Dose of Much-Anticipated Guidance
April 12, 2011 Legal Alert: Resetting the FBAR: Foreign Financial Account Reporting Regulations are Finalized With Significant, But Not Always Helpful, Clarifications
March 4, 2011 Legal Alert: Many Happy (Consolidated) Returns or 'Til "DIT" Do Us Part? Final Treasury Regulations Address Intercompany Items of Gain on Member Stock
March 4, 2011 Legal Alert: Much Anticipated Guidance Concerning the Federal Tax Classification of Series Issued
September 15, 2010 Legal Alert: ISDA Protocol Addresses New Withholding Rules for Dividend Equivalent Payments
September 1, 2010 Legal Alert: IRS Issues Welcome Guidance Regarding Treatment of Releases of Property Securing REMIC Loans
August 26, 2010 Legal Alert: FATCA Proposed Legislation Enacted as Part of HIRE Act
March 18, 2010 Legal Alert: Significant Changes Made to FATCA Legislation as Part of House Passed Extenders Bill
December 11, 2009 Legal Alert: Significant Proposed Legislation Would Increase Compliance Costs for U.S. Payors and Impact Worldwide Recipients of U.S. Source Income
November 10, 2009 Legal Alert: IRS Advice Signals Policy Change That Permits Tax-Free Exchanges of Trademarks, Trade Names and Other Customer-Based Intangibles
March 18, 2009 Legal Alert: Counterparty Rights in the Lehman Brothers Bankruptcy
October 10, 2008 Legal Alert: Lehman Brothers Bankruptcy-ISDA Issues
September 15, 2008 Legal Alert: Supreme Court Rejects Pre-Confirmation Tax Exemptions
June 18, 2008 Legal Alert: Proposed Amendments to REMIC Regulations Published Today
November 9, 2007 Publications Economic Substance Directive: Some Substance, Many Questions
August 22, 2011 Reposted with permission State Tax Notes "Prevention of Mismatching of Interest and OID Deductions and Income Inclusions in Transactions with Related Foreign Persons" in "Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 P.L. 108-357," Vol. 45, No. 25 Tax Management Memorandum 563 (2004) "Proposed Contingent Notional Principal Contract Regulations (Warning: Don't Try This at Home)" Vol. 17, No. 5 Journal of Taxation and Regulation of Financial Institutions 36 (2004) Co-author, "Regulations Proposed to Nullify Certain 'Disregarded Entity' Elections" Vol. 29, No. 3 Tax Management International Journal 131 (2000) Co-author, "The Administration's Corporate Tax Shelter Proposals: What are the Limits of Appropriate Tax Planning Vol. 40, No.7 Tax Management Memorandum S-99 (1999) Note, "Rate Review: Applying Chevron Deference to FERC Determination of its Jurisdiction" 64 George Washington Law Review 1195 (1996) Events Tax Executives Institute: 62nd Midyear Conference
March 25-28, 2012 TEI New Orleans: International Tax Developments Day
February 1, 2012 Sutherland Tax Series: Session II
December 6, 2011 Sutherland Tax Series I: Mergers and Acquisitions
November 30, 2011 TEI Annual Conference
October 30-November 2, 2011 TEI Seattle Chapter SALT Meeting
September 26, 2011 Sutherland SABLE Program
July 13, 2011 TerraLex Annual Meeting
June 3, 2011 TEI Seattle Chapter State and Local Tax Update
February 9, 2011 TEI St. Louis Chapter Meeting
November 17, 2010 TEI 60th Midyear Conference
April 11-14, 2010 Webinar: Pending Tax Initiatives
July 28, 2009 TEI European Chapter Winter Conference
January 28-29, 2008 |