Mr. Lady represents clients engaging in tax-free reorganization transactions involving both domestic and foreign participants. Mr. Lady also provides advice concerning taxable transactions, including tax planning associated with Internal Revenue Code Section 338.

Mr. Lady’s representation of non-U.S. clients includes providing advice with respect to the Foreign Investment in Real Property Tax Act (FIRPTA), the portfolio interest exemption to U.S. withholding tax, application of the “U.S. trade or business” rules, the U.S. branch profits tax, and the application of the U.S. income tax treaty network. Mr. Lady also has experience assisting U.S. clients with the rules applicable to controlled foreign corporations and passive foreign investment companies.

Mr. Lady’s practice also includes assisting clients with requesting private letter rulings from the Internal Revenue Service on various matters, preserving tax attributes in the Chapter 11 bankruptcy context, tax considerations associated with the choice of legal entity, and the proper taxation of damages and settlement awards.