With more than 30 years of experience in international business tax planning and controversy, Randy Buchanan guides multinational corporations through the intricacies of US and foreign tax and accounting considerations as a trusted advisor in order to achieve their business objectives in a tax-efficient manner. Randy is highly effective at counseling multinational corporations on complex, high-stakes federal and international tax matters with global implications. These matters include the ever-changing OECD landscape, operational and supply chain planning, transfer pricing, treaty considerations, mergers and acquisitions, dispositions, reorganizations, spin-offs, joint ventures, post-acquisition integration, restructurings, Subpart F planning, financing transactions and currency issues. Randy is also an expert at managing and advising on direct and indirect tax audits and controversies, particularly when they involve multiple jurisdictions.
Awards and Rankings
Recognized by The Legal 500 United States in the area of tax: international (2011)
Experience
“I enjoy developing creative ways for clients to achieve their business objectives in a tax efficient manner without taking unnecessary risks.”
Experience
Served as Kraft Foods' tax counsel in Cadbury acquisition.
Served as tax counsel to Philip Morris in Indonesian cigarette company acquisition.
Served as tax counsel to Altria in Philip Morris spin-off deal.
Acted as tax counsel in $25 billion spinoff.
Advised Altria in UST acquisition.
Represented Philip Morris International as tax counsel in international transaction.
Represented Philip Morris as tax counsel in purchase of Canada’s Rothmans, Inc.
Represented Kraft in spin-off of Post cereals business.
Aided Altria and Kraft in the $15 billion acquisition of Nabisco and subsequent Kraft IPO.
Served as Altria's tax counsel in Miller Brewing sale.
Served as tax counsel to Altria in its approximately $50 billion spin-off of Kraft.
Acted as tax counsel for 3M in $1.2 billion Aearo acquisition.
Served as tax counsel to Mondelez International in the 2015 formation of the $5 billion Jacobs Douwe Egberts global coffee joint venture with D.E. Master Blenders.
News
In the News
Taxation With Representation: Tax Counsel On The Deal (December 6, 2013)
Law360
Sutherland’s representation of Philip Morris International Inc. was featured in Law360’s weekly column, “Taxation with Representation,” for their helping the company purchase a stake in a Russian ...
Press Releases
Eversheds Sutherland Successfully Completes Public Listing of Columbia Care (May 16, 2019)
Eversheds Sutherland is pleased to announce that it has successfully completed a public listing of Columbia Care Inc., on the Canadian NEO Stock Exchange. Columbia Care is the first company with an ...
Sutherland Makes Mark in The Legal 500 for 2011 (December 1, 2011)
ATLANTA (December 1, 2011) - This year, eight Sutherland Asbill & Brennan LLP practices and 24 attorneys ranked nationally in The Legal 500 United States 2011. The firm received national rankings in: ...
Presentations
Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax (November 6-7, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax on November 6-7, 2018, in Seattle, Washington. Presentations can be ...
Federal Tax Day (June 26, 2018)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) Partners Randy Buchanan, Robb Chase, Ellen McElroy and Aaron Payne present “FDII Sense” and “Practical Impacts of the TCJA on Existing Domestic Operations” at TEI Silicon ...
Related Party Debt: Regulations Propose Sweeping Changes (May 25, 2016)
TEI Fort Worth Chapter Meeting
Sutherland attorneys Randy Buchanan and Taylor Kiessig present Related Party Debt: Regulations Propose Sweeping Changes at the TEI Fort Worth Chapter Meeting on May 25, 2016, in Fort Worth, Texas.
Publications
Legal Alerts
Surprise! Section 901(m) final regulations (April 3, 2020)
Surprisingly, in the midst of the COVID-19 emergency, final regulations under Section 901(m) were published. While important for M&A transactions, Section 901(m) had largely been treated as an ...
Fine tuning the course-Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions (November 19, 2019)
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 9859) (the Final Regulations) modifying the application of section 956 ...
Fine-tuning the course-Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions (11/1/2019)
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 ...
Legal Alert: Fine-tuning the course-Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions (May 30, 2019)
On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 ...
LB&I announces new campaigns - Related-party service companies, offshore private banking and loose-filed Forms 5471 (April 25, 2019)
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: Transfer pricing ...
The Second Circuit - canons of construction prevail in dizzying case of “black hole” tax refunds (April 4, 2019)
In an important win for taxpayers, a unanimous Second Circuit reversed the Tax Court on a statutory interpretation issue involving the three-year “look-back” period for Tax Court jurisdiction over ...
Trend reversed - No German royalty withholding tax on online advertising services (March 25, 2019)
In collaboration with Eversheds Sutherland attorneys Dr. Stefan Diemer and Joerg Kaessner .
After German tax authorities in the state of Bavaria and others had begun to order some German companies, as part of ongoing audit procedures, to retroactively pay German withholding tax at a rate of ...
The Last Piece of the Puzzle-the Section 250 Proposed Regulations (March 12, 2019)
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section ...
A (new) German digital advertisement tax? German tax authorities start to impose withholding tax on cross-border online advertising (February 28, 2019)
In collaboration with Eversheds Sutherland attorneys Dr. Stefan Diemer and Joerg Kaessner .
German tax authorities have started utilizing existing income tax rules to impose royalty withholding tax on cross-border digital advertising services. According to news reports, tax authorities in ...
We are not in Kansas anymore - OECD proposes way forward for digital tax solution (February 1, 2019)
The Organisation for Economic Co-operation and Development (OECD) has issued a policy note document (Note) addressing the tax challenges of the digitalization of the economy under its action plan ...
Articles
OECD Consults on Taxing the Digitalized Economy (March 29, 2019)
Bloomberg Daily Tax Report
On February 13, 2019, the OECD released a public consultation paper titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (Consultation). The Consultation follows the policy ...
