REPRESENTATIVE EXPERIENCE
Paul’s representative experience includes:
- Providing advice to Great-West Lifeco and its U.S. affiliates on tax issues relating to the $3.9 billion acquisition of Putnam Investments.
- Providing advice to Manulife Financial Corporation and its U.S. affiliates on tax issues relating to a 1.2 billion Canadian dollar cross-border financing transaction.
- Providing tax advice to United States Oil Fund, an exchange-traded vehicle (ETV) that was the first exchange-traded partnership designed to track changes in crude oil prices.
- Providing tax advice to a major multi-national insurance company on securitization transactions involving transfer of risks relating to guaranteed level premium insurance policies subject to NAIC Regulation XXX and AXXX to the capital markets.
- Advising several major insurance companies on tax issues raised by innovative annuity products with a guaranteed minimum withdrawal benefit feature.
- Negotiating favorable administrative settlements with the IRS for a domestic insurance company with respect to a tax-advantaged financial transaction, and for a U.S. subsidiary of a foreign corporation with respect to cross-border financing transactions involving hybrid instruments.
- Assisting several Fortune 500 companies in negotiating tax provisions of Schedules to ISDA Master Agreement with dealer counterparties.
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Member, Taxation and Financial Transactions Committee, Taxation Section, American Bar Association
- Member, District of Columbia Bar
RECENT SPEAKING ENGAGEMENTS
- Speaker, “Current Developments in Financial Products and Transactions,” Tax Executives Institute (TEI), Houston, Texas (May 2007)