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William Chip
William W. Chip
Senior Counsel
Washington +1 202 662 5229 wchip@cov.com Download V-card

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.

  • 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.
  • For the foreign owner of a U.S. affiliated group, negotiated the first-ever IRS Pre-Filing Agreement confirming that the owner satisfied the "limitation on benefits" test of a U.S. tax treaty.
  • For a U.S. 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 U.S. subsidiary could be deducted by its U.S. branch, reversing an earlier, contrary published position of the IRS.
  • For a U.S. 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 U.S. manufacturer, developed a supply-chain transfer pricing strategy for its foreign subsidiaries that accelerated utilization of U.S. net operating losses and reversal of associated valuation allowances.
  • For a major European bank, developed a plan for the tax-efficient combination of U.S. business activities conducted in branch and subsidiary form.
  • For a multinational agribusiness company, developed and supervised implementation of plans for the tax-efficient acquisition of a global competitor and the tax-efficient integration of legacy subsidiaries in Europe and the Americas.
  • For a state-owned, Middle Eastern oil company, developed an offshore strategy for the tax-efficient commercialization of intangible property.
  • For a multinational U.S. oil company, managed and brought to a successful conclusion income tax audits spanning 11 taxable years.
  • For a prominent national charity, advised and aided the Board of Directors in controlling the financial, tax, and reputational consequences of defalcations by a senior executive.
  • For a leading international financial institution, designed a partnership strategy for preservation of tax attributes of an acquired U.S. business.
  • 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)