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Todd is chair of Taft’s Tax practice and focuses his work on general corporate taxation and international tax matters. He frequently represents clients with respect to domestic and cross-border M&A, inbound investment by non-U.S. persons, taxation of financial instruments and foreign currency denominated investments, choice of legal entity and the application of the United States tax-treaty network.

A significant component of Todd’s practice includes advising U.S. clients with respect to the U.S. reporting of foreign activities, representing clients in seeking administrative relief through the private ruling process and representing clients under examination by the IRS. Todd’s practice also includes assisting clients with preserving tax attributes in connection with financial restructurings and the proper taxation of damage awards and settlements.

Todd’s experience includes representing both FORTUNE 500 companies and closely held businesses with respect to corporate and international tax matters. He is a frequent speaker on the topics of corporate and international taxation and a member of the Council of the Taxation Section of the Indiana State Bar Association. Todd has been recognized by Best Lawyers in America® for tax law and has been selected by Law & Politics Magazine as an Indiana Rising Star in tax. He is also a member of the firm’s Executive Committee.

A common investment structure presented to domestic tax-exempt entities involves investing in flow-through operating businesses through a “blocker corporation.” Avoiding unrelated business taxable income (“UBTI”) is a key focus for many tax-exempt entities. By investing through a blocker corporation, the blocker corporation pays any applicable income tax and then passes on the remaining profits to the tax-exempt entity as a dividend. Corporate dividends are considered passive income and as such, are not subject to the UBIT tax, except in limited

Continue Reading Did you know some U.S. tax-exempt entities may be disadvantaged by investing through an offshore corporate blocker?

The recent U.S. Supreme Court ruling in Bittner v. United States (No. 21-1195 (U.S. Feb. 28, 2023)) significantly impacts U.S. taxpayers with “undisclosed” offshore bank and other financial accounts. Under the Bank Secrecy Act (the “BSA”), U.S. persons that own interests in (or have certain authority with respect to) foreign bank or financial accounts with a balance in excess of $10,000 at any time during the year generally must disclose the existence and balance of such accounts to the U.S.
Continue Reading Did you know a recent Supreme Court ruling dramatically reduced penalties for non-willful failures to report foreign bank accounts?