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 and speaks regularly on a variety of federal income tax topics.

Representative Matters

• Timber products company -- advise concerning US tax aspects of conversion to a REIT, including issues of qualification, US withholding and shareholder treatment.
• 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 integration of foreign operations following a multi-billion dollar acquisition.
• Numerous companies -- advised on structuring domestic and foreign JVs and limited liability companies. 
• Clean energy companies -- structuring to ensure availability of treasury grants, investment tax credit, and production tax credit.

Honors and Rankings

• Chambers USA, Tax (2010-2011)

Memberships and Affiliations

• Georgetown University Law Center, Adjunct Professor of Law (2004-2010)
• International Bar Association, Member

Publications and Speeches

• "Recent IRS Guidance Concerning Section 48C Manufacturing Credit Reminds that Standard for a "Significant Change" is Low, but Indicates Willingness to Consult with DOE on Whether Changes are Significant," Covington E-Alert (1/5/2011), Co-Author
• "The American Jobs and Closing Tax Loopholes Act of 2010 - Expected and Unexpected International Proposals," Covington E-Alert (5/20/2010), Co-Author
• "Government Incentives For Renewable Energy - An Update," Covington Advisory (3/16/2010), Co-Author