Daniel Luchsinger

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, clean energy, 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 -- advised on US tax aspects of foreign amalgation.
• Manufacturer -- led project and advised on US tax aspects of restructuring involving European and Asian operations.
• Beverage company -- advised on US tax aspects of financing and structuring multi-billion dollar corporate and JV acquisition and operation.
• Beverage company -- advised on US tax aspects of foreign restructuring necessitated by the 2008 credit crisis, including: company restructuring; restructuring of intercompany lending arrangements (including currency aspects of such arrangements); and restructuring of intercompany and third party hedges.
• Manufacturer -- advised on US tax aspects of transfers of intangible property to foreign JVs.
• Energy company -- advised on US tax aspects of JV formation involving renewable fuels after 2009 stimulus bill.
• Energy company -- secured IRS ruling involving internal spin-offs.
• Clean energy company -- advised on availability of new credits resulting from 2009 stimulus bill.

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.

• "Application Process Opens for Qualifying Advanced Energy Project Tax Credits," Covington E-Alert (8/18/2009), Co-Author
• "Department of Energy Opens Application Process for Billions In Loan Guarantees And Exercises Recovery Act Loan Guarantee Authority For The First Time; Treasury Opens Application Process for Renewable Energy Grants in Lieu of Tax Credits," Covington E-Alert (8/3/2009), Co-Author
• "Treasury Publishes Eagerly Anticipated Guidance Concerning Renewable Energy Grants Under the American Recovery and Reinvestment Act Of 2009," Covington E-Alert (7/10/2009), Co-Author