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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Recognition


  • The Best Lawyers in America 2005 to 2019, Tax Law
  • Chambers Global, 2001 to 2016, Tax: Corporate & Finance and International Tax
  • Chambers USA, 2003 to 2018, 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

August 25, 2015

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

July-August, 2015

Structural Changes in Light of BEPS

July 6, 2015

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

May - June 2015

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

April 10, 2015

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

March-April 2015

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

March 13, 2015

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

January-February, 2015

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

November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

November - December, 2014

“Inversion”: A Cross-Border Acquisition Structure

December 12, 2014

IRS Challenges Characterization of Distribution as a Return of Basis

October 10, 2014

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

September - October 2014

Recent Transfer Pricing Cases

July-August 2014

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

August 8, 2014

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

June 13, 2014

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

May - June 2014

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

April 30, 2014

Properly Valuing Intangibles Transferred to Foreign Subsidiaries

April 11, 2014

Exiting a Joint Venture Partnership That Owns a Foreign Subsidiary

April 3, 2014

Exiting a Joint Venture Partnership That Owns a Foreign Subsidiary

March - April 2014

Recent LTRs Apply Subpart F Manufacturing Exceptions

February 14, 2014

Subpart F Manufacturing Exception Applied to Products That Are Grown

February 7, 2014

Subpart F Manufacturing Exception Applied to Products That Are Grown

January - February 2014

Code Sec. 956 Traps

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