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Mr. Luchsinger practices in a broad range of federal income tax issues, including the structuring of partnerships and joint ventures; corporate acquisitions and corporate dispositions; planning international and cross border financings; restructurings involving foreign withholding, subpart F minimization, and foreign tax credit utilization; inbound and outbound property transfers; and foreign ownership of United States real property. Mr. Luchsinger advises clients in a number of industries, including oil and gas, mining, manufacturing and consumer products. In addition to his consulting practice, Mr. Luchsinger assists taxpayers with audits and appeals, including drafting of written responses and direct negotiations with examiners and appeals agents. Mr. Luchsinger also teaches Taxation of Partnerships at the Georgetown University Law Center.
Representative Matters
- Foreign gold mining company – lead US tax counsel in three way amalgamation.
- Oil and gas company – tax counsel in IRS fast track negotiations involving EOR credits.
- Beverage company – US tax counsel in connection with $2 billion foreign joint venture acquisition.
- Insurance Company – representation in connection with IRS audit of complex partnership structure.
- Spirit company – lead US tax counsel in connection with restructuring of European and Asian operations.
- Oil and gas company – lead tax counsel in connection with $6.6 billion acquisition of Canadian Oil Sands.
- Steel producer – lead tax counsel in connection with $1.9 billion acquisition of Canadian steel producer.
- Spirits company – lead tax counsel in connection with $220 million partial liquidation, including an IRS ruling.
- Manufacturer – lead US tax counsel in connection with restructuring of European and Asian operations.
- Energy company – representation in connection with IRS ruling involving internal spin-offs.
Previous Experience
- Miller & Chevalier, Partner (1998-2008)
- Zapruder & Odell, Partner (1992-1998)
Memberships and Affiliations
- Georgetown University Law Center, Adjunct Professor of Law (2004-2008)
- International Bar Association, Member
Publications and Speeches
- Mr. Luchsinger speaks regularly on a variety of federal income tax topics, including most recently, at the North Carolina TEI chapter and for the American Petroleum Institute.
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