Christopher has advised a wide array of clients including public and private corporations, private equity funds, and portfolio companies on a broad range of corporate, partnership, and US international tax planning and transaction tax matters.
Christopher focuses on delivering practical, business-oriented tax solutions across the full transaction lifecycle, and assists in the development, negotiation, and drafting of the tax aspects of transaction legal agreements including equity & asset sale and purchase agreements, mergers agreements, and operating agreements. Christopher also supports clients by drafting technical opinions and memorandum, assisting clients in drafting representation letters, and assisting in the procurement of representations and warranties insurance. Christopher has experience counseling clients across numerous industries including healthcare, energy, regulated utilities, transportation, manufacturing, pharmaceuticals, technology, and retail.
Christopher’s experience covers a wide gambit of subject matter areas including broad subchapter C issues, consolidated return planning, taxable acquisitions and divestitures, tax-free acquisitions and divestitures, tax-free spin-offs, “friendly doctor” tax structures, cancellation of indebtedness and attribute planning, cash repatriation strategies, Section 382 and Section 385 considerations, subchapter K issues, S corporation acquisitions and divestitures, and fund formation matters for private equity sponsors and their portfolio companies.
Prior to joining McGuireWoods, Christopher spent nearly a decade advising clients at Big Four accounting firms where he also advised clients on a multitude of transaction tax matters including the tax structuring and execution of complex and high-profile transactions, including multi-billion-dollar acquisitions, dispositions and integrations, public spin-offs and reverse Morris Trust transactions, cross-border fund formations, Section 382 planning, and out-of-court debt restructurings.
- Advised on the multi-hundred-million-dollar divestiture of a multi-national publicly traded company’s non-core school bus business via a “sell-the-seller” tax structure.*
- Structured a multi-billion-dollar acquisition of a corporate practice of medicine business and the integration of such business within the acquirer’s pass-through structure.*
- Advised on a multi-national out-of-court debt restructuring with inversion, significant debt modification, cancellation of indebtedness, and attribute planning implications.*
- Advised on multiple billion-dollar minority interest divestitures by regulated utility companies.*
- Advised a multi-billion-dollar international chemical conglomerate on the divestiture of one of its sub-business lines recently acquired in a reverse Morris Trust transaction.*
- Advised on numerous cross-border fund formations, fund continuations, and investment divestiture transactions.*
- Advised an international payment solutions company’s consolidation of multiple business lines under a single domestic holding company in advance of a multi-billion-dollar initial public offering.*
- Managed the tax structuring for a publicly traded manufacturing company’s multi-billion-dollar reverse Morris Trust transaction supported by a private letter ruling.*
- Managed the tax structuring for a publicly traded global manufacturer’s multi-hundred-million-dollar carve-out and cross-border disposition of its automotive division.*
- Managed the tax structuring for a take-private of a publicly traded multi-billion-dollar multinational water purification company and integration of such company within an existing private equity fund structure.*
- Supported a global insurance company in its multi-billion-dollar spin-off of its U.S. retail business.*
* Completed prior to joining McGuireWoods.
Events
- Presenter, "Accounting Considerations in Tax Transactions," Tax Executive Institute Conference, August 2024
Insights
- Author, A High-Class Solution to a Low-Class Problem: Recent Private Ruling Indicates IRS’s Expansive Approach to ELA Blending Rules, Journal of Corporate Taxation, 45 WGL-CTAX 37, May 2018