William W. Chip

Partner

wchip@cov.com
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Covington & Burling LLP
1201 Pennsylvania Avenue, NW
Washington, DC 20004-2401
Tel: 202.662.5229
Mobile: 202.253.5567
Fax: 202.778.5229


 

Practices

Education

  • Yale Law School, J.D., 1979
    • Yale Law Journal, Editor
  • Cambridge University, M.A., 1973
    • first class honours
  • Yale University, B.A., 1971
    • magna cum laude
    • Phi Beta Kappa

Bar Admissions

  • District of Columbia
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals for the Federal Circuit
  • U.S. Supreme Court

Languages

  • Spanish


Bill Chip is the firm’s senior international tax partner and resides in the firm’s Washington office.  Mr. Chip has over thirty years of tax experience, including nine years as a global audit firm partner and eighteen as a law firm partner.  Over the course of his career, Mr. Chip has represented and advised many of the largest multinational companies headquartered in the United States and European Union, including companies in the financial services, life sciences, and oil industries.  He advises Tax Directors, General Counsels, and CFOs on the international tax aspects of business globalization, strategic acquisitions and joint ventures, integration of acquired and pre-existing businesses, and the use of complex financial instruments for corporate finance and risk management.  He has achieved favorable settlements of complex international tax controversies with the IRS examination and appeals divisions, in the courtroom, and in Competent Authority proceedings.  A preeminent transfer pricing expert, Mr. Chip regularly manages global transfer pricing projects that cover planning, documentation, audit defense, and negotiation of Advance Pricing Agreements.  In matters involving tax jurisdictions outside the United States and United Kingdom, Mr. Chip relies on a well-established network of eminent foreign tax attorneys and often collaborates with one or more of the Big Four accounting firms.  As a long-serving member of the Business and Industry Advisory Committee (BIAC) to the Organization for Economic Cooperation & Development (OECD), he has been an active participant in the ongoing debate over Base Erosion and Profit Shifting (BEPS).  Prior to entering law school, Mr. Chip served as an officer in the U.S. Marine Corps, attaining the rank of Captain.

Representative Matters

  • For the US subsidiary of a large Asian industrial company, negotiated a “no change” settlement to an IRS-proposed equity reclassification of hundreds of millions of dollars of parent-guaranteed debt.
  • For a Middle Eastern chemical distribution company, designed and helped to implement a global marketing structure that minimized permanent establishment and transfer pricing risk.
  • For the foreign owner of a US affiliated group, negotiated the first-ever IRS Pre-Filing Agreement confirming that the owner satisfied the "limitation on benefits" test of a US tax treaty.
  • For a US bank seeking to acquire a troubled competitor, negotiated a unique IRS ruling that only bad debt losses realized in the first post-acquisition year would be subject to "built-in loss" limits on deductibility.
  • For a large EU institution, obtained an IRS ruling that the net operating losses of a liquidated US subsidiary could be deducted by its US branch, reversing an earlier, contrary published position of the IRS.
  • For a US multinational, secured from the IRS a landmark private letter ruling holding that a foreign subsidiary's sale of stock in active foreign subsidiaries does not convert the selling corporation into a passive foreign investment company.
  • Pioneered a "virtual contract manufacturing" strategy that has been implemented by several Fortune 500 industrial companies.
  • For a large US manufacturer, developed a supply-chain transfer pricing strategy for its foreign subsidiaries that accelerated utilization of US net operating losses and reversal of associated valuation allowances.

Previous Experience

  • Deloitte & Touche, Partner (1995-2004)

Honors and Rankings

  • Listed as a Leading American Tax Lawyer by Chambers USA (2007-2014)
  • Recommended by Legal 500, Tax (2012-2013) 
  • Recognized in Best Lawyers in America (2013)
  • Named as a Leader in the Field by The International Who’s Who of Corporate Tax Lawyers (2013).
  • U.S. Defense Department, Citation for Meritorious Public Service (2006)

Pro Bono

  • General Counsel, Marine Toys for Tots Foundation
  • General Counsel, National Football League Alumni (1995-2010)
  • Tax Counsel, Foundation for International Community Assistance

Memberships and Affiliations

  • American Bar Association Tax Section, OECD Subcommittee, Chairman
  • U.S. Council for International Business, Transfer Pricing Subcommittee, Co-Chairman
  • OECD Business & Industry Advisory Committee, Tax Committee
  • Institute of International Bankers, Professional Liaison Committee
  • International Fiscal Association, Member
  • TransAtlantic Business Dialogue, U.S. Tax Issues Manager (1999-2004)
  • European American Business Council, Tax Committee, Chairman (1999-2005)

Publications and Speeches

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