William Chip

William W. Chip

Senior Counsel

wchip@cov.com
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Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-4956
Tel: +1 202 662 5229
Fax: +1 202 778 5229

   

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

Languages

  • Spanish

Bill Chip advises and represents the owners and executives of emerging and established multinational enterprises in the design, execution, and defense of their global tax strategies. As a long-serving member of the OECD’s Business and Industry Advisory Committee (BIAC), Mr. Chip has been an active participant in the ongoing Base Erosion and Profit Shifting (BEPS) process that is reshaping the global tax planning landscape.


Representative Matters

  • For a U.S. based biotech company, engineered a transfer of offshore intellectual property into a tax-advantaged jurisdiction and a subsequent spin-off and IPO.
  • For a Latin American multinational, designed and implemented a globally tax-efficient structure for licensing and lending to Latin American affiliates through the U.S. branch of a Spanish ETVE.
  • 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 entrepreneurs in the banking and biotech industries, devised a structure for safely transforming foreign services and royalty income into low-taxed qualified dividend income with a credit for foreign income taxes at the entity level.
  • For the U.S. 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.

Previous Experience

  • Deloitte & Touche, Partner (1995-2004)

Honors and Rankings

  • Listed as a Leading American Tax Lawyer by Chambers USA (2007-2014).
  • Named as a Leader in the Field by Who’s Who Legal: Corporate Tax Lawyers (2013-2014).
  • 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
  • Capital Pro Bono Honor Roll (2011-2014)

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

  • "The Economic Substance Doctrine," Tax Management Portfolio 508-2d (2015), Author
  • "Transfer Pricing: OECD Transfer Pricing Guidelines," Tax Management Portfolio 6936 (2015), Author
  • "Virtual Contract Manufacturing: The Last Frontier?," Tax Notes International (7/9/2012), Author
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