Overview


Lowell D. Yoder focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, e-commerce, financial, consumer and industrial companies. He advises on tax-efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax-beneficial planning for intangible holding companies, global supply chains and multi-jurisdictional service arrangements. Lowell also represents clients before the Internal Revenue Service (IRS), handling audits and obtaining tax rulings. He works with an extensive network of lawyers worldwide, developing tax-favorable transactional and operational cross-border structures. Lowell previously served as the global head of the Firm’s Tax Practice.

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Results


  • Advising Joh. A. Benckiser on a tax-efficient acquisition structure for the purchase of a $12.5 billion global business, and developing tax-beneficial post-acquisition integration structures
  • Advising a client on structuring the global ownership of high-value intangibles, minimizing foreign and US tax codes
  • Representing before the IRS two multinational companies in connection with hundreds of millions of dollars of proposed tax adjustments with respect to business operations conducted outside the United States

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Recognitions


  • The Best Lawyers in America 2005 to 2020, Tax Law
  • Chambers Global, 2001 to 2016, Tax: Corporate & Finance and International Tax
  • Chambers USA, 2003 to 2019, TaxStar Individual (as of 2018)

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Community


  • American Bar Association, chair of the Subcommittee for Controlled Foreign Corporations, PFICs and Contract Manufacturing, and of the Committee on Foreign Activities of US Tax Payers
  • American College of Tax Counsel, fellow
  • GWU/IRS Annual Institute on International Taxation, member of the advisory board

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Credentials


Education
University of Illinois College of Law, JD, magna cum laude, 1982
University of Illinois at Chicago, BS, highest distinction, 1979

Admissions
Illinois

Courts / Agencies
US Tax Court
US Court of Appeals for the Fourth Circuit
US Internal Revenue Service
US Court of Appeals for the Ninth Circuit

Lowell D. Yoder

Insights & Events / Media

Chicago, IL / Speaking Engagements / September 2, 2020

Bloomberg Tax / September 13, 2019

Chicago, IL / Alumni Events / September 4, 2019

International Tax Journal / July / August 2019

International Tax Journal / June 2019

Bloomberg Tax International Journal / May 8, 2019

Chicago, IL / McDermott Event / May 8, 2019

International Tax Journal / March/April 2019

Washington, DC / Speaking Engagements / April 1, 2019

Bloomberg Tax Management International Journal / March 1, 2019

Washington, District of Columbia / Speaking Engagements / December 13, 2018

Chicago, Illinois / Speaking Engagements / November 9-10, 2018

Bloomberg Tax: Tax Management International Journal / November 9, 2018

On the Subject / May 11, 2018

Global Tax Weekly / April 29, 2018

International Tax Journal / March-April 2018

Bloomberg BNA Tax Management International Journal / April 13, 2018

On the Subject / March 28, 2018

Washington, District of Columbia / Speaking Engagements / March 25-28, 2018

International Tax Journal / January-February 2018

Taxnet Pro / February 8, 2018

On the Subject / February 6, 2018

Bloomberg BNA Daily Tax Report / January 22, 2018

Taxnet Pro / January 18, 2018

On the Subject / January 17, 2018

On the Subject / December 17, 2017

Bloomberg BNA Tax Management International Journal / December 8, 2017

Washington, District of Columbia / Speaking Engagements / November 30 - December 1, 2017

International Tax Journal – A Note from the Editor in Chief / November 2017

Bloomberg BNA Daily Tax Report / November 21, 2017

Toronto, Canada / Speaking Engagements / October 22-25, 2017

International Tax Journal, A Note from the Editor-in-Chief / September/October 2017

Chicago, Illinois / Speaking Engagements / September 11, 2017

Bloomberg BNA Tax Management International Journal / August 11, 2017

Bloomberg BNA International Tax Management Journal / June 9, 2017

Bloomberg BNA International Tax / May 3, 2017

Bloomberg BNA Tax Management International Journal / April 14, 2017

Bloomberg BNA Tax Management International Journal / April 2017

Santa Clara, California / Speaking Engagements / March 23, 2017

Bloomberg BNA Tax Management International Journal / February 10, 2017

Bloomberg BNA International Tax Journal (Note from the Editor in Chief) / February 10, 2017

Bloomberg BNA Premier International Tax Library / December 20, 2016

Tax Law Journal (Columbia Law School) Volume 8, Number 1 / December 2016

International Tax Journal (A Letter from the Editor-in-Chief) / November/December 2016

Bloomberg BNA International Tax Library / November 1, 2016

International Tax Journal (Note from the Editor in Chief) / September/October 2016

Bloomberg BNA International Tax Library / August 11, 2016

Global Tax Weekly (Wolters Kluwer) / August 4, 2016

International Tax Journal (A Note from the Editor in Chief) / July/August 2016

Bloomberg BNA International Tax Library / June 9, 2016

CCH International Tax Journal (A Noted from the Editor-in-Chief) / May-June 2016

Bloomberg BNA Tax Management International Journal / April 8, 2016

Commerce Clearing House (CCH) Taxes – The Tax Magazine / March 2016

Bloomberg BNA International Tax Library / February 8, 2016

Commerce Clearing House (CCH) Note from the Editor-in-Chief / January/February 2016

Bloomberg BNA International Tax Library / December 9, 2015

Commerce Clearing House (CCH) International Tax Journal / November/December 2015

Commerce Clearing House (CCH) International Tax Journal / September/October 2015

Bloomberg BNA International Tax Library / October 9, 2015

Bloomberg BNA / August 25, 2015

Does §956 Apply to Rev. Proc. 99-32 Deemed Receivables?

International Tax Journal / July-August, 2015

Structural Changes in Light of BEPS

Bloomberg BNA / July 6, 2015

IRS Provides Guidance for Calculating the Subpart F Branch Rule's Tax Rate ...

International Tax Journal / May - June 2015

Obama Administration Proposes a 19-Percent Minimum Tax on Foreign Earnings

Bloomberg BNA's Tax Management International Journal / April 10, 2015

Proposed New Subpart F Income Category: ‘Foreign Base Company Digital Income’

International Tax Journal / March-April 2015

IRS Expands the Application of the Code Sec. 956 Anti-Conduit Rule

Tax Management International Journal / March 13, 2015

Section 956: IRS Treats Foreign Property as U.S. Property

International Tax Journal / January-February, 2015

Cross-Border Hybrid Financing Arrangements (a note from the Editor-in-Chief)

Publications / November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

International Tax Journal / November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

Tax Management International Journal, Bloomberg BNA / December 12, 2014

IRS Challenges Characterization of Distribution as a Return of Basis

Bloomberg BNA, Tax Management International Journal / October 10, 2014

IRS Applies the §956 Indirect Investment Rule to a Partnership Loan

International Tax Journal / September - October 2014

Recent Transfer Pricing Cases

International Tax Journal / July-August 2014

No Subpart F Income if No Related Party Purchase or Sale of ...

Bloomberg BNA, Tax Management International Journal / August 8, 2014

President's Budget Would Apply Subpart F to Toll Manufacturing Arrangements

Leading Practitioner Commentary, Tax Management International Journal, Bloomberg BNA / June 13, 2014

Subpart F Treatment of Gain on the Sale of Property Leased or ...

International Tax Journal / May - June 2014

The Unique Treatment of Code Sec. 367(d) Deemed Payments

Tax Notes Today / April 30, 2014

Properly Valuing Intangibles Transferred to Foreign Subsidiaries

Tax Management International Journal / April 11, 2014

Exiting a Joint Venture Partnership That Owns a Foreign Subsidiary

Bloomberg BNA / April 3, 2014

Exiting a Joint Venture Partnership That Owns a Foreign Subsidiary

International Tax Journal / March - April 2014

Recent LTRs Apply Subpart F Manufacturing Exceptions

Bloomberg BNA Tax Management International Journal / February 14, 2014

Subpart F Manufacturing Exception Applied to Products That Are Grown

Bloomberg BNA's International Tax News / February 7, 2014

Subpart F Manufacturing Exception Applied to Products That Are Grown

International Tax Journal / January - February 2014

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