REPRESENTATIVE EXPERIENCERobb’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, “The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings,” BNA Insights (International)—Bloomberg BNA Tax and Accounting Center (June 2012)
- Co-author, “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,” BNA Insights (Federal)—Bloomberg BNA Tax and Accounting Center (April 2012)
- Co-author, “A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss ‘Supersecret Rule,’” BNA Insights (Federal)—Bloomberg BNA Tax and Accounting Center (April 2012)
- 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, “Tax Considerations in Due Diligence and Documentation of Mergers and Acquisitions,” TEI Dallas Tax School (April 23, 2013)
- Speaker, “2013 International Tax Hot Topics,” TEI Cincinnati Chapter (April 22, 2013)
- Speaker, “You Can’t Spell Subchapter C without E&P,” TEI 63rd Midyear Conference (March 17-20, 2013)
- 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)
