Atlanta GEORGIA

ABOUT Reginald J. Clark

An early interest in business law ultimately led Reggie Clark to Eversheds Sutherland (US)'s Tax Practice Group, where he counsels a variety of corporate clients on the complex tax issues that affect corporate acquisitions, restructurings, spinoffs and other transactions. Reggie also advises clients in tax disputes, often serving as their representative before the National Office of the Internal Revenue Service (IRS) in connection with ruling or technical advice requests. In addition to corporate clients, Reggie represents university endowment fund managers on the taxation and legal issues associated with private equity and other investments.

Reggie is a former adjunct professor of law in Emory University School of Law’s graduate tax program.

Awards and Rankings

According to Chambers USA, Reggie Clark is “highly regarded” and “is commended for his work on corporate taxation and transactional matters.”

Recognized by The Legal 500 United States in the area of domestic tax (2015); tax - U.S. taxes: non-contentious (2016); and international tax (2017)

Recognized byChambers USA: Guide to Leading Business Lawyers in the area of tax (2003-2020)

Selected for inclusion inPLC Which Lawyer? Yearbook for Tax (2008)

Recognized as “Lawyer of the Year” by The Best Lawyers in America in the area of tax law (2016)

Named to The Best Lawyers in America in the area of tax law (2007-2020)

Selected for inclusion in Georgia Super Lawyers (2004-2019)

Experience

“Advising clients on corporate and transactional tax matters, from routine tax planning to mergers and acquisition, is like working on an intricate puzzle. You have to pull just the right pieces together to ensure the proper outcome.”

Experience

Advised Wendy's/Arby's Group Inc. on tax issues related to sale of Arby's to Roark Capital.
Secured tax-exempt status for new supporting organization of a university-affiliated health system.
Provided tax employee benefits advice to CCE in split-off of international bottling operations.
Represented South Carolina pediatric dental practices in connection with the sale of those businesses to an Atlanta-based Dental Support Organization.
Represented Southeastern Mills, Inc., a leading food products company, in the sale of its custom coatings and seasonings division to Kerry Inc.
Represented TRP Construction Group, a leading provider of traffic control solutions, in its acquisition of Tolle Roads, LLC.

News

In the News

A Step in the Right Direction: IRS Rules on North-South Spinoffs (September 2017)
Lexis Federal Tax Journal Quarterly
Eversheds Sutherland’s legal alert, A Step in the Right Direction: IRS Rules on North-South Spinoffs, is featured in the September 2017 edition of Lexis Federal Tax Journal Quarterly.

Press Releases

24 Eversheds Sutherland Practice Areas, 63 Attorneys Named Among Nation’s Best in 2020 Chambers USA (April 23, 2020)
Eversheds Sutherland is pleased to announce that 24 practices and 63 attorneys have earned recognition in the 2020 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers USA, a ...

Eversheds Sutherland Represents Lion in Acquisition of New Belgium Brewing (December 2, 2019)
Eversheds Sutherland is pleased to announce that it represented Lion Little World Beverages (LWB), part of Lion’s global craft division, in entering into a definitive agreement for LWB to acquire ...

19 Eversheds Sutherland Practice Areas, 55 Attorneys Named Among Nation’s Best in 2019 Chambers USA (April 25, 2019)
Eversheds Sutherland is pleased to announce that 19 practices and 55 attorneys have earned recognition in the 2019 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers USA, a ...

27 Eversheds Sutherland Attorneys Named 2019 Georgia Super Lawyers and Rising Stars (February 7, 2019)
Eversheds Sutherland is pleased to announce that 25 of its attorneys based in Georgia have been selected as top attorneys in the state by Super Lawyers . Additionally, two attorneys have been ...

19 Eversheds Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2018 Chambers USA (May 3, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 19 practices and 59 attorneys have earned recognition in the 2018 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers ...

30 Eversheds Sutherland (US) Attorneys Named 2018 Georgia Super Lawyers and Rising Stars (February 23, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 25 of its attorneys based in Georgia have been selected as top attorneys in the state by Super Lawyers . Additionally, five attorneys have ...

Four Eversheds Sutherland Attorneys Named Lawyer of the Year; 80 Lawyers Recognized in 2018 Edition of The Best Lawyers in America (August 15, 2017)
Eversheds Sutherland is pleased to announce that four attorneys have been selected as “Lawyer of the Year” in their respective fields by The Best Lawyers in America, and 80 attorneys have been ...

19 Eversheds Sutherland (US) Practice Areas, 58 Attorneys Named Among Nation’s Best in 2017 Legal 500 United States (May 31, 2017)
Eversheds Sutherland (US) LLP is pleased to announce that 19 practice areas and 58 attorneys have been ranked in the 2017 edition of The Legal 500 United States. Legal 500 is a comprehensive survey ...

20 Eversheds Sutherland (US) LLP Practice Areas, 56 Attorneys Named Among Nation’s Best in 2017 Chambers USA (May 26, 2017)
Eversheds Sutherland (US) LLP is pleased to announce that 20 practices and 56 attorneys at the firm earned recognition in the 2017 edition of Chambers USA: America’s Leading Lawyers for Business. ...

31 Eversheds Sutherland (US) Attorneys Named 2017 Georgia Super Lawyers and Rising Stars (February 21, 2017)
ATLANTA-Eversheds Sutherland (US) LLP is pleased to announce that 27 of the firm’s attorneys based in Georgia have been selected as top attorneys in the state by Super Lawyers. Additionally, four ...

Presentations

“I enjoy the variety in my practice, from advising large corporations on the tax issues in mergers and acquisitions to counseling university endowments on the taxation of their investments.”

Presentations

LIBOR Replacement and US Tax Law Considerations for Multi-Currency and Cross-Border Financing Transactions (September 13, 2018)
Austin Business Law Conference
Eversheds Sutherland (US) Partners Christina Rissler and Reggie Clark and attorneys Jessica Rissmiller and Lizet Steele, with material assistance from Kimia Basyuk, present on LIBOR Replacement and ...

Sutherland's Year-End Tax Seminar (December 6, 2016)
Sutherland hosts and leads a Year-End Tax Seminar on December 6, 2016, in Philadelphia, Pennsylvania. Topics include:Federal Tax Partnership DevelopmentsSpeaker: Karl ...

Recent Federal Income Tax Developments (February 17, 2015)
TEI Atlanta
Sutherland Partners Reggie Clark, Danny McKeithen and Joe Depew present Recent Federal Income Tax Developments at TEI Atlanta in Atlanta, Georgia on February 17. In this present, Reggie, Danny and ...

Taxable Merger and Acquisition Structures (April 2-3, 2009)
ALI-ABA Program on Corporate Taxation
Sutherland Partner Reginald Clark presented a CLE course for ALI titled Taxable Merger and Acquisition Structures. The course is designed to help both in-house corporate tax counsel and managers ...

Common Merger and Acquisition Structures (April 2008)
American Law Institute-American Bar Association Program on Corporate Taxation

Publications

“Tax issues-and the implications they bring to the client-are always changing. That makes my practice especially challenging and, as a result, especially interesting.”

Legal Alerts

Whose Loss Is it Anyway? Losses in M&A after the CARES Act (April 23, 2020)
Net operating losses (NOLs) of a corporation are often one of its most significant tax attributes and may be a meaningful economic driver in a disposition of the corporation or its assets. The Tax ...

Party Like It’s 1986: Business Impacts of the Bill Formerly Known as the Tax Cuts and Jobs Act (December 22, 2017)
On December 22, 2017, the President signed into law the bill formerly known as the Tax Cuts and Jobs Act (the Final Bill), which was passed by the House of Representatives and the Senate earlier in ...

Reconciling the Differences, the Senate Tax Cuts and Jobs Act (November 16, 2017)
On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a ...

How a Framework Becomes a Law: House Republicans Release Tax Reform Bill (November 7, 2017)
On November 2, 2017, Republicans on the House Ways and Means Committee released their much anticipated tax reform bill, titled the Tax Cuts and Jobs Act (as modified by Chairman Brady on November 3 ...

Partnership Tax Allocations: Recent IRS CCA Scrutinizes Purported Loss Allocations of a Non-US Partnership (October 31, 2017)
Chief Counsel Advice 201741018 (the CCA), which was released on October 13, 2017, considers the manner in which losses of a non-US partnership should be allocated among the partnership’s US and ...

Getting Something for Nothing: IRS Withdraws Proposed “Net Value” Regulations (July 19, 2017)
On July 12, the Internal Revenue Service (IRS) withdrew long-standing proposed regulations that would have required an exchange or distribution of “net value” for corporate liquidations, formations ...

Treasury Identifies Significant Regulations Subject to Modification or Repeal (July 13, 2017)
On July 7, 2017, Treasury identified eight significant regulations, including regulations under sections 385 (treatment of certain debt as equity), 752 (partnership liabilities), 367 (outbound ...

Legal Alert: A Step in the Right Direction: IRS Rules on North-South Spinoffs (May 22, 2017)
The Internal Revenue Service (IRS) recently released guidance on certain “north-south” spinoff transactions. Generally, a “north-south” transaction consists of a transfer of property from a ...

Opting-In: Treasury Regulations Provide Rules for Electing into the New Partnership Audit Regime Early (August 15, 2016)
As reported in a prior Sutherland Legal Alert, the Bipartisan Budget Act of 2015 (the 2015 Budget Act) makes significant changes to the procedural rules governing federal income tax audits and ...

White House Issues Guidance Advising Agencies to Assess Climate Change in NEPA Reviews (August 11, 2016)
On August 1, the White House Council on Environmental Quality (CEQ) issued its final guidance for federal agencies on considering greenhouse gas (GHG) emissions and the effects of climate change in ...

Articles

The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshuffling (2012)
Bloomberg BNA Tax and Accounting Center
Members of Sutherland's Tax Practice Group authored an article, titled The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings, that was ...

You Can't Spell Subchapter C Without E&P: Proposed Treasury Regulations Clarify The Rules Concerning The Allocation Of Earnings And Profits In Tax-Free Transfers (2012)
Bloomberg BNA Tax and Accounting Center
Some practitioners have concluded that earnings and profits of an acquired corporation may be allocated between multiple corporations following a reorganization and a related contribution of less ...

A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss 'Supersecret Rule' (2012)
Bloomberg BNA Tax and Accounting Center
Nearly a year after issuing proposed regulations that aimed to modify the so-called supersecret rule of Treas. Reg. 1.267(f)-1(c)(1)(iv) (the Proposed Regulations), Treasury and the Internal ...

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Areas of LAW

  • Environmental
  • Tax

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