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Dan Luchsinger chairs the firm's Tax Practice Group. He practices in a broad range of federal income tax issues, including the structuring of partnerships and joint ventures; domestic and cross-border acquisitions and dispositions, including both inbound and outbound property and stock transfers; and cross-border restructurings seeking sustainable tax attribute utilization and effective tax rate minimization. Mr. Luchsinger regularly oversees multijurisdictional acquisitions and restructurings, drawing on a network of advisors of the highest caliber from around the world.
Mr. Luchsinger advises both U.S. and Non-U.S. clients in a number of industries ranging from consumer products to heavy manufacturing, including companies operating through tax advantaged vehicles. For almost a decade, Mr. Luchsinger taught Taxation of Partnerships at the Georgetown University Law Center and speaks regularly on a variety of federal income tax topics.
- Bacardi – lead tax attorney advising Bacardi on its multi-billion dollar acquisition and integration of Swiss-based Patrón.
- Weyerhaeuser – lead tax attorney advising Weyerhaeuser on its multi-billion dollar merger and integration of Plum Creek timberlands.
- Timken – tax advice concerning the tax free separation of Timken’s steel business from its other businesses.
- Weyerhaeuser – tax advice concerning the tax free separation and merger of Weyerhaeuser's home building business with Tri Point home builders.
- Weyerhaeuser – tax advice concerning the acquisition and rationalization of Longview Timberlands.
- Norfolk Southern – various transactions involving subsidiaries and partnership holdings.
- Manufacturer – led project and advised on U.S. tax aspects of restructuring involving India manufacturing subsidiaries.
- Manufacturer – led project and advised on U.S. tax aspects of restructuring involving European and Asian operations.
- Beverage company – advised on U.S. tax aspects of financing and structuring multi-billion dollar corporate and JV acquisition and operation.
- Beverage company – advised on U.S. tax aspects of post-acquisition integration of foreign operations following a multi-billion dollar acquisition.
- Numerous companies – advised on structuring domestic and foreign JVs and limited liability companies.
Memberships and Affiliations
- IBA Taxes Committee, Secretary (2020-present)
- Georgetown University Law Center, Adjunct Professor of Law (2004-2012)
January 2021
Recapture of Excess COVID-19 Payroll Tax Credits Addressed in New Regs As the legal, regulatory, and commercial implications of coronavirus COVID-19 continue to evolve, our lawyers and advisors are helping clients navigate the complex considerations that companies around the world are facing and develop plans and strategies in response. Reach out to our ...
March 26, 2020, Covington Alert
Late last night, the Senate passed (96-0) the Coronavirus Aid, Relief, and Economic Security ("CARES") Act that was introduced by several Senate Republicans last Thursday. This follows a number of days of whirlwind negotiations, beginning with the Senate where, on Sunday night, a procedural vote failed to garner the 60 votes necessary to move the legislation ...
March 16, 2020, The Wall Street Journal
Daniel Luchsinger is quoted in The Wall Street Journal regarding the effects of the Tax Cuts and Job Act on businesses in the wake of coronavirus losses. The article states that the 2017 tax code overhaul is making life harder for U.S. businesses who have suffered losses and are seeking liquidity. Mr. Luchsinger says, “You want some safety valve in the system ...
March 12, 2020, Covington Alert
The Tax Cuts and Jobs Act (“TCJA”) made significant changes to the tax code, a number of which can have unexpected effects when a company loses money in the United States or abroad. While the immediate concerns around the spread of COVID-19 are rightfully focused on public health and welfare, given the current economic fallout arising from COVID-19, companies ...
October 14, 2019, Covington Alert
The European Union directive known as DAC 6 requires EU “intermediaries” (including advisors, banks and businesses) to disclose to EU tax authorities details of any cross-border arrangements which feature a reportable “hallmark”.
Former Treasury Official Rejoins Covington
October 1, 2019
WASHINGTON—Lindsay Kitzinger, who until recently was an Attorney Advisor in the Office of International Tax Counsel, within the U.S. Treasury's Office of Tax Policy, has rejoined Covington as a partner in its Tax Practice Group in Washington. During her time at Treasury, Ms. Kitzinger was involved in the tax reform legislation that was enacted in December 2017, ...
March 18, 2019
NEW YORK—Kevin Zaragoza has joined Covington's Tax Practice Group as a partner in New York. Mr. Zaragoza's arrival follows the recent addition of tax partner Kevin Otero also in New York. Mr. Zaragoza concentrates on the domestic and cross-border tax aspects of mergers and acquisitions, leveraged buy-outs, dispositions, minority investments, partnership and ...
February 21, 2019
WASHINGTON—Covington advised the Chicago Cubs and Northside Entertainment Holdings, LLC in the formation of a joint venture with Sinclair Broadcast Group that will own and operate Marquee Sports Network, a regional sports network based in Chicago. Marquee Sports Network will be the exclusive network of the Chicago Cubs beginning with the 2020 Major League ...
Comments on Section 59A Proposed Regulations (Internal Revenue Service REG–104259–18) – Applicability of BEAT to Global Services Provided by U.S. Equipment Manufacturers
February 19, 2019, Covington Comment Letter
Covington Nabs Tax Partner From PwC For NY Office
February 4, 2019, Law360
Law360 covered Kevin Otero’s move to the firm as a partner in our tax practice group. Mr. Otero will represent large corporations and individuals before the IRS. He also will advise and represent clients before the U.S. Tax Court, U.S. Court of Federal Claims, and federal district and appellate courts across the country. He says, “There’s been a lot of ...
Leading Tax Lawyer Joins Covington
February 1, 2019
NEW YORK—Kevin Otero has joined Covington's Tax Practice Group as a partner in New York. Mr. Otero advises clients on all aspects of tax controversy matters including audits, administrative appeals, transfer pricing controversies, and tax litigation. He also has extensive experience advising clients on technical tax risk management, strategic audit and ...
January 9, 2019, Covington Alert
On January 2 of this year, former House Ways & Means Chairman Kevin Brady (R-TX) introduced the Tax Technical and Clerical Corrections Act. It contains technical corrections to existing tax law, many of which relate to Public Law 115–97, also known as the Tax Cuts and Jobs Act (TCJA) of 2017. Mr. Brady introduced this measure as a discussion draft and has ...
December 19, 2018
NEW YORK—Covington advised Tetragon Financial Group Limited on the merger of its GreenOak Real Estate joint venture with Bentall Kennedy, Sun Life Financial Inc.’s North American real estate and property management firm. The combined entities will be called Bentall GreenOak. Tetragon will remain an investor in Bentall GreenOak, which the merger values at $940 ...
August 9, 2018
WASHINGTON—Covington advised Emergent BioSolutions in its $270 million acquisition of PaxVax. PaxVax is majority owned by an affiliate of Cerberus Capital Management. Emergent is a global life sciences company focusing on providing specialty products for civilian and military populations that address public health threats. PaxVax is a company focused on ...
Treatment of Section 78 Gross-Up Amounts Relating to Section 960(b) Foreign Income Taxes
July 22, 2018, Covington White Paper
Proposed Guidance Regarding the Treatment of Income from Banking Under Section 199A
June 7, 2018, Covington Comment Letter to The Honorable David J. Kautter and The Honorable William M. Paul
January 22, 2018
WASHINGTON—Covington advised Bacardi Limited in its definitive agreement to acquire Patrón Spirits International AG and its PATRÓN® brand, the world’s top-selling ultra-premium tequila, from John Paul DeJoria, a founder of Patrón. The transaction reflects an enterprise value for Patrón of $5.1 billion. The transaction follows the successful relationship the ...
February 6, 2017, Covington Alert
The new Trump Administration has generated significant uncertainty about the applicability of a number of tax regulations finalized in the waning days of the Obama Administration. On the day of President Trump’s inauguration, Reince Priebus, the Chief of Staff of the White House issued a memorandum to all the heads of executive agencies to pause certain of their ...
September 30, 2015
NEW YORK - Covington advised the underwriters in the $106.1 million initial public offering by Austrian-based Nabriva Therapeutics AG of 10,350,000 million American Depositary Shares, representing 1,035,000 shares of Nabriva’s common stock. This was the first U.S. initial public offering by an Austrian company. The ADSs are now listed on the NASDAQ Global Market ...
8/4/2014
WASHINGTON, DC, August 4, 2014 — Covington & Burling is pleased to announce that Sam Maruca, most recently the Director of Transfer Pricing Operations for the Large Business and International Division at the U.S. Internal Revenue Service, has returned to the firm as a partner. Mr. Maruca will be resident in the firm’s Washington D.C. office, and will advise ...
Treasury Official Lee Kelley Joins Covington
December 3, 2013
WASHINGTON, DC, December 3, 2013 — Lee Kelley, most recently deputy tax legislative counsel in the U.S. Department of Treasury’s Office of Tax Policy, has joined Covington & Burling as a partner in the firm’s tax practice. Ms. Kelley, who has extensive expertise in consolidated returns and subchapter C, will focus on corporate tax matters, including structural ...
June 18, 2013
WASHINGTON, DC, June 18, 2013 — Covington & Burling is advising ING Insurance International on the sale of its mortgage business in Mexico, ING Hipotecaria, to the Mexican banking subsidiary of Banco Santander, Spain’s largest bank, for approximately $50 million. The team is led by Gabriel Mesa and includes corporate associates Cecile Zwiebach, Dan Levine and ...
August 30, 2012
WASHINGTON, DC, August 30, 2012 — Michael Caballero, the former international tax counsel at the U.S. Treasury Department, will be joining Covington & Burling and its tax practice. Mr. Caballero will be based in the firm’s Washington office as a partner effective September 10. At the Treasury Department, Mr. Caballero served as one of the administration’s most ...
8/2/2012
SAN FRANCISCO, August 2, 2012 — Covington & Burling represented Borrego Solar Systems, Inc. in connection with its new $64.4 million project finance fund with partners U.S. Bank and National Cooperative Bank. The fund will be used to build more than 18 megawatts of solar energy systems, including systems to be located at four municipal landfill installations and ...
Covington Advises Borrego Solar in Financing Transaction
3/1/2012
SAN FRANCISCO, March 1, 2012 — Covington & Burling LLP represented Borrego Solar Systems, Inc. in connection with its new $47 million project finance fund with partners U.S. Bank and East West Bank. The fund will finance solar energy projects that are expected to create hundreds of new jobs and generate electricity to power nearly 2,000 homes. Borrego Solar is ...
November 2, 2011
SAN FRANCISCO, November 2, 2011 — Covington & Burling LLP represented Microsoft Corporation in the sale of its minority interest in ContentGuard Holdings, Inc. to Pendrell Technologies LLC. ContentGuard, based in El Segundo, Calif., is a leading inventor, developer and licensor of digital rights management (DRM) and related content distribution patents and ...
Covington Advises Microsoft in Standards-Essential Wireless Patents Portfolio Transaction with MOSAID and Nokia
September 2, 2011
SAN FRANCISCO, September 2, 2011 — Covington & Burling LLP represented Microsoft Corp. in a patent monetization transaction involving the acquisition by MOSAID Technologies Incorporated of Core Wireless Licensing S.a.r.l., a Luxembourg company that holds a portfolio of 400 patent families, consisting of approximately 2,000 wireless patents and patent ...
June 29, 2011
WASHINGTON, DC, June 29, 2011 — Covington & Burling LLP represented National Geographic Society in its agreement with Cengage Learning to sell its digital and print school publishing unit and to extend additional rights to use the National Geographic brand in higher education and library markets worldwide. National Geographic’s school publishing unit includes ...
June 10, 2011
WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 123 individual mentions and 45 practice mentions in Chambers USA 2011. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington lawyers and practices ...
June 9, 2011
WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 92 individual mentions and 32 practice mentions in the Legal 500 US 2011 edition. Legal 500 reviews the strengths and strategies of law firms in more than 90 countries in Europe, the Middle East, Asia, North and South America, and the Caribbean. Here are the Covington lawyers and practices ...
June 16, 2010
WASHINGTON, DC, June 16, 2010 — Covington & Burling LLP received 112 individual mentions and 44 practice mentions in Chambers USA 2010. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington lawyers and practices ...
May 20, 2010, Covington E-Alert
August 18, 2009, Covington E-Alert
July 10, 2009, Covington E-Alert
IRS Publishes Guidance for Electing ITC In Lieu of PTC for Certain Renewable Energy Facilities
June 10, 2009, Covington E-Alert
October 7, 2008, Covington E-Alert
Covington Adds Two Partners to Washington Tax Group
7/15/2008
WASHINGTON, DC, July 15, 2008 — Covington & Burling LLP is pleased to announce that Sam Maruca and Dan Luchsinger have joined the firm as tax partners. Both will reside in the firm’s Washington office. Reeves Westbrook, chair of Covington’s tax practice, commented: “Sam and Dan are top-flight international tax lawyers. Sam’s exceptional experience in managing ...
- Chambers USA, Tax (2010-2019)
- Legal 500 US, Tax (2012-2017)
- Washington DC Super Lawyers, Tax (2013-2015, 2017-2019)
- Washingtonian, Tax "Top Lawyer" (2018)
COVID-19: Legal and Business Toolkit
We are helping clients around the world navigate this evolving, complex situation.