With more than 20 years of experience, Robb counsels multinational corporations in all aspects of structuring, negotiating, documenting and reporting cross-border transactions, and he has represented 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. Robb works with clients across all industries, including manufacturing, retail, e-commerce, technology, communications and professional services.
Awards and Rankings
Selected for inclusion in Washington, DC, Super Lawyers (2013-2015)
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 international tax (2011, 2016-2018); U.S. taxes: non-contentious (2018); and domestic tax (2015)
“We understand that tax is just one consideration in every business transaction. We make it a point to know the business objectives of our clients so that we can achieve the best overall tax result that is consistent with the company’s business objectives. Understanding our clients’ businesses is as important as understanding the tax law.”
Served as U.S. tax counsel for multinational European acquisition.
Served as tax counsel to TE Connectivity in $1.25 billion cash merger acquisition of ADC Telecommunications.
Served as U.S. tax counsel in $3 billion credit agreement for Altria.
Advised Altria in UST acquisition.
Acted as tax counsel in $25 billion spinoff.
Served as tax counsel to Altria in Philip Morris spin-off deal.
Advised P&G on tax considerations in 100 billion debt issue.
Served as Kraft Foods' tax counsel in Cadbury acquisition.
Served as tax counsel to Philip Morris in Indonesian cigarette company acquisition.
Represented Philip Morris International as tax counsel in international transaction.
Represented Philip Morris as tax counsel in purchase of Canada’s Rothmans, Inc.
Represented Kraft in spin-off of Post cereals business.
Aided Altria and Kraft in the $15 billion acquisition of Nabisco and subsequent Kraft IPO.
Served as tax counsel to Altria in its approximately $50 billion spin-off of Kraft.
Served as Altria's tax counsel in Miller Brewing sale.
Acted as tax counsel for 3M in $1.2 billion Aearo acquisition.
Advised TE Connectivity stakeholders on tax matters resulting from domicile change.
Acted as special tax counsel to Altria in $1.5 billion debt offering.
Acted as special tax counsel to Altria in $200 million debt offering.
Acts as special tax counsel to PMI in debt offerings worth an aggregate $1.25 billion.
Advised Philip Morris in Colombian tobacco acquisition.
Served as U.S. tax counsel in PMI's US$2 billion amended and restated revolving credit facility.
Advised privately held conglomerate in connection with cost sharing arrangements and transfer pricing.
Advised multinational manufacturing and technology company in connection with audit of certain transfer pricing matters and availability and consequences of correlative adjustments.
Advised cable telecommunications company on cost sharing and transfer pricing arrangements in connection with international operations.
Advised multinational manufacturing and technology company on competent authority considerations relating to proposed IRS settlement.
Advised leading electronic commerce company and its subsidiaries in connection with global sales, procurement and contracting activities, including intercompany arrangements.
Advised an American paint manufacturer in connection with transfer pricing questions raised in audit and potential competent authority considerations.
“We regularly advise multinational corporations on their cross-border transactions. This means working closely with trusted advisors in other jurisdictions to ensure the most efficient transaction structure from a U.S. and a local tax perspective.”
Legal Alert: Spinning in circles, Treasury resumes original course on regulated investment company income rules (March 25, 2019)
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test ...
Legal Alert: The Last Piece of the Puzzle-the Section 250 Proposed Regulations (March 12, 2019)
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section ...
Legal Alert: We are not in Kansas anymore - OECD proposes way forward for digital tax solution (February 1, 2019)
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan ...
Legal Alert: And the BEAT goes on - proposed regulations clarify the application of the base-erosion and anti-abuse tax (December 20, 2018)
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under section 59A of the Internal Revenue Code of 1986, as amended, ...
Legal Alert: The season of giving - proposed regulations ease FATCA reporting burdens (December 20, 2018)
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of ...
Legal Alert: Allocation, apportionment and attribution, oh my - Proposed foreign tax credit regulations provide critical guidance (December 3, 2018)
On November 28, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations concerning foreign tax credit determinations and related issues ...
Legal Alert: INXS? IRS issues proposed regulations under section 163(j) (November 29, 2018)
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue ...
Legal Alert: Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of certain shareholders (November 6, 2018)
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of ...
Legal Alert: GILTI by consolidation (September 25, 2018)
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department ...
Legal Alert: In transition-proposed section 965 regulations incorporate and expand on prior guidance (August 20, 2018)
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 ...
Thinking Inside the Box: Tax Reform Proposals Consider “Patent” and “Innovation” Boxes (Summer 2015)
In their article for the Summer 2015 edition of Partnering Perspectives, Robb Chase and Taylor Kiessig explore the “patent box” or “innovation box,” which offers a significant reduction in U.S. tax ...
Tax Court Holds Rev. Proc. 99-32 Accounts Receivable Constitute Related-Party Indebtedness for Purposes Of 965 (December 13, 2013)
Tax Management International Journal
The United States Tax Court concluded that the taxpayer’s accounts receivable in BMC Software Inc. v. Commissioner, established between itself and its controlled foreign corporation pursuant to Rev. ...
The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshuffling (2012)
Bloomberg BNA Tax and Accounting Center
Members of Sutherland's Tax Practice Group authored an article, titled The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings, that was ...
You Can't Spell Subchapter C Without E&P: Proposed Treasury Regulations Clarify The Rules Concerning The Allocation Of Earnings And Profits In Tax-Free Transfers (2012)
Bloomberg BNA Tax and Accounting Center
Some practitioners have concluded that earnings and profits of an acquired corporation may be allocated between multiple corporations following a reorganization and a related contribution of less ...
A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss 'Supersecret Rule' (2012)
Bloomberg BNA Tax and Accounting Center
Nearly a year after issuing proposed regulations that aimed to modify the so-called supersecret rule of Treas. Reg. 1.267(f)-1(c)(1)(iv) (the Proposed Regulations), Treasury and the Internal ...
Economic Substance Directive: Some Substance, Many Questions (August 22, 2011)
Reposted with permission State Tax Notes
The FBAR Reset: Final Regulations Provide Mixed Guidance (April 25, 2011)
Proposed Contingent Notional Principal Contract Regulations (Warning: Don’t Try This at Home) (2004)
Vol. 17, No. 5, Journal of Taxation and Regulation of Financial Institutions 36
Prevention of Mismatching of Interest and OID Deductions and Income Inclusions in Transactions with Related Foreign Persons (2004)
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
Regulations Proposed to Nullify Certain ‘Disregarded Entity’ Elections (2000)
Vol. 29, No. 3, Tax Management International Journal 131
Eversheds Sutherland Global Tax Brief (December 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...
Eversheds Sutherland Global Tax Digest (March 2017)
Introducing the Eversheds Sutherland Global Tax Digest-a collection of tax developments from our attorneys across the globe. With the combination of Eversheds and Sutherland came expanded ...
Partnering Perspectives: Law and Technology (Summer 2015)
Sutherland is pleased to present the latest edition of Partnering Perspectives, which explores innovative efforts to use the law to affect policy and control the abuse of technology. Articles ...
“The work is intellectually challenging, and our team approach-working closely with our colleagues in the firm and our clients-makes it interesting and exciting.”
Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax (November 14, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax on November 14, 2018, in Philadelphia, Pennsylvania. Presentations ...
Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax (November 6-7, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax on November 6-7, 2018, in Seattle, Washington. Presentations can be ...
Panel regarding Section 951A of the Internal Revenue Code (October 17, 2018)
FBA Section on Taxation Breakfast
Daniel Nicholas and Robb Chase present on a panel covering Section 951A of the Internal Revenue Code at the FBA Section on Taxation Breakfast on October 17, 2018, in Washington, DC.
US Tax Reform Conference 2018 (September 17, 2018)
AICPA and CIMA
Eversheds Sutherland is the proud lead sponsor of the Association of International Certified Professional Accountants (AICPA) and the Chartered Institute of Management Accountants (CIMA) US Tax ...
Federal Tax Day (June 26, 2018)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) Partners Randy Buchanan, Robb Chase, Ellen McElroy and Aaron Payne present “FDII Sense” and “Practical Impacts of the TCJA on Existing Domestic Operations” at TEI Silicon ...
2018 TEI Region II Tax Forum (June 4-5, 2018)
Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary ...
State and Local Tax Day (May 15, 2018)
Tax Executives Institute (TEI) Denver Chapter
Eversheds Sutherland (US) attorneys Michele Borens, Robb Chase, Maria Todorova, Ted Friedman and Alla Raykin present at the Tax Executives Institute (TEI) Denver Chapter State and Local Tax Day on ...
Eversheds Sutherland Year-End Tax Seminar (November 10, 2017)
Eversheds Sutherland hosts and leads a Year-End Tax Seminar on November 10, 2017, in Malvern, Pennsylvania. Topics include: “The ‘Avrahami’ Case and Its Potential Impact on Non-Micro ...
TEI Seattle Chapter Meeting (September 19, 2017)
Tax Executives Institute, Inc. (TEI)
Eversheds Sutherland (US) is a proud sponsor of the TEI Seattle Chapter Meeting taking place September 19, 2017, in Seattle, Washington. The Eversheds Sutherland SALT Team presents:“State and ...
2017 TEI Region II Tax Forum (June 5 - 6, 2017)
Eversheds Sutherland is a proud co-sponsor of the 2017 TEI Region II Tax Forum taking place June 5-6, 2017, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include five plenary ...
“We are a firm that works to our strengths-particularly tax, insurance, SEC, regulatory and energy-and we are leaders in these fields.”
In the News
IRS Rules Threaten Broad Reach for Interest Deduction Cap (November 28, 2018)
Eversheds Sutherland Partner Robert Chase is quoted in this Law360 article discussing the recent Treasury and Internal Revenue Service (IRS) proposed regulations restricting deductions for interest ...
IRS, Treasury Float Rules on Foreign Earnings Under Tax Reform (August 2, 2018)
Eversheds Sutherland Partner Robert Chase is quoted in this Compliance Week article discussing the proposed regulations focus on Section 965 of the Internal Revenue Code (IRS) as amended by the ...
Axing Deadwood Tax Regulations of Little Use to Businesses (February 15, 2018)
Eversheds Sutherland Partner Robert Chase is quoted in this Law360 article regarding the US Department of Treasury's regulatory review and its current proposal to cull nearly 300 outdated tax ...
Eversheds Sutherland Observations on the Unified Tax Framework (October 4, 2017)
Eversheds Sutherland’s legal alert, Big Six Releases Tax Framework: It’s Time to Get Dynamic, is featured in Captive.com.
Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities (March 2017)
Lexis Federal Tax Journal Quarterly
Eversheds Sutherland (US)’s legal alert, “Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities,” is featured in the March 2017 edition of Lexis Federal Tax ...
Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes (June 2016)
Lexis Federal Tax Journal Quarterly
Sutherland’s legal alert, “Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes,” is featured in the June 2016 edition of Lexis Federal Tax Journal Quarterly.
Eversheds Sutherland Represents Cox Enterprises in Sale of Majority Stake in Cox Media Group Television Stations to Apollo Global Management (March 5, 2019)
Eversheds Sutherland is pleased to announce that it represented Cox Enterprises on their agreement with funds managed by Apollo Global Management, LLC (Apollo) to buy a majority interest in Cox Media ...
18 Eversheds Sutherland Practice Areas, 68 Attorneys Named Among Nation’s Best in 2018 Legal 500 United States (May 30, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 18 practice areas and 68 attorneys have been recognized in the 2018 edition of The Legal 500 United States, a comprehensive survey of legal ...
19 Eversheds Sutherland (US) Practice Areas, 58 Attorneys Named Among Nation’s Best in 2017 Legal 500 United States (May 31, 2017)
Eversheds Sutherland (US) LLP is pleased to announce that 19 practice areas and 58 attorneys have been ranked in the 2017 edition of The Legal 500 United States. Legal 500 is a comprehensive survey ...
16 Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2016 Legal 500 United States (June 16, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 16 practice areas and 59 attorneys have been ranked in the 2016 edition of The Legal 500 United States. Legal 500 is ...
14 Sutherland Practice Areas, 62 Attorneys Named Among Nation’s Best in 2015 Legal 500 United States (June 4, 2015)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 14 practice areas and 62 attorneys have been ranked in the 2015 edition of The Legal 500 United States, a ...
23 Sutherland Attorneys Named 2015 Washington, DC, Super Lawyers and Rising Stars (April 23, 2015)
WASHINGTON (April 23, 2015)-Sutherland Asbill & Brennan LLP today announced that 19 of the firm’s attorneys based in Washington, DC, have been selected as top attorneys in the state by Super ...
Challenge Accepted: Sutherland Offices Complete ALS Ice Bucket Challenge, Raise Funds for Charity (August 29, 2014)
ATLANTA, AUSTIN, HOUSTON, NEW YORK, SACRAMENTO and WASHINGTON-The Atlanta, Austin, Houston, New York, Sacramento and Washington offices of Sutherland Asbill & Brennan LLP recently accepted challenges ...
26 Sutherland Attorneys Named 2014 Washington, DC, Super Lawyers and Rising Stars (May 9, 2014)
WASHINGTON - Sutherland Asbill & Brennan LLP today announced that 20 of the firm’s attorneys based in Washington, DC, have been selected as top attorneys in the state by Super Lawyers. ...
125 Sutherland Attorneys Named Super Lawyers and Rising Stars in 2013 (May 28, 2013)
ATLANTA and WASHINGTON (May 28, 2013) - Sutherland Asbill & Brennan LLP announced today that 119 of the firm’s lawyers were chosen as top attorneys and Rising Stars by Super Lawyers. The designations ...
86 Sutherland Attorneys Named as “Best Lawyers in America (November 5, 2012)
ATLANTA and WASHINGTON (November 5, 2012) - In the 2013 edition of The Best Lawyers in America, 86 Sutherland Asbill & Brennan LLP attorneys are recognized as leaders in their field. The publication ...
Podcast: Likely impact of US tax reform on multinationals (December 13, 2018)
In this topical podcast, our global tax team discusses the likely impact the recent US tax reforms will have for multinationals. Join Ben Jones, Sebastiano Sciliberto, Marco Melisse, Torsti Lakari, ...
Webcast: Hot Topics in the Taxation of Private Investment Funds (March 13, 2013)
Sutherland Partners Robb Chase, Bob Copps and David Roby will address recent regulatory and legislative developments affecting the taxation of private investment funds. In particular, the program ...
Podcast: Taxes Turn: Legislative Proposals to Reform Taxation of Financial Instruments (January 31, 2013)
On January 24, 2013, the Chairman of the U.S. House Ways and Means Committee issued a discussion draft of proposed legislation that would reform the taxation of financial products, including debt ...
Podcast: Over the Hedge: Current Tax Considerations in the Structure and Operations of Hedge Funds and Other Private Funds (July 17, 2012)
Please join Sutherland's Private Funds Team for a webinar regarding current tax considerations in the structure and operation of hedge funds and other private funds. This program will provide an ...
Member, American Bar Association
Member, District of Columbia Bar
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