Robb Chase helps multinational companies with significant operations in the United States plan their transactions-acquisitions, dispositions, joint ventures, restructurings and finance company arrangements-to achieve desired business objectives in the most tax-efficient manner. He routinely assists clients in navigating the rapidly changing maze of international tax rules and regulations that apply to multinational businesses, and provides advice on the implications of US tax reform and non-US tax changes in response to the Organisation for Economic Co-operation and Development’s Base Erosion and Profit Shifting initiative.
With more than 20 years of experience, Robb counsels multinational corporations in all aspects of structuring, negotiating, documenting and reporting cross-border transactions, and he has represented taxpayers in complex tax audit and litigation matters.
Robb regularly advises clients on tax issues relating to domestic and foreign public and private debt offerings, synthetic and hybrid instruments, foreign currency transactions, swaps and derivatives, hedging transactions and other complex financial products and transactions. Robb works with clients across all industries, including manufacturing, retail, e-commerce, technology, communications and professional services.
Awards and Rankings
Selected for inclusion in Washington, DC, Super Lawyers (2013-2015)
Named among Washington, D.C.’s “40 Under 40” by Legal Times magazine (2009)
Recognized by The Legal 500 United States in the area of international tax (2011, 2016-2019); U.S. taxes: non-contentious (2018-2019); and domestic tax (2015)
Experience
“We understand that tax is just one consideration in every business transaction. We make it a point to know the business objectives of our clients so that we can achieve the best overall tax result that is consistent with the company’s business objectives. Understanding our clients’ businesses is as important as understanding the tax law.”
Experience
Served as U.S. tax counsel for multinational European acquisition.
Served as tax counsel to TE Connectivity in $1.25 billion cash merger acquisition of ADC Telecommunications.
Served as U.S. tax counsel in $3 billion credit agreement for Altria.
Advised Altria in UST acquisition.
Acted as tax counsel in $25 billion spinoff.
Served as tax counsel to Altria in Philip Morris spin-off deal.
Advised P&G on tax considerations in 100 billion debt issue.
Served as Kraft Foods' tax counsel in Cadbury acquisition.
Served as tax counsel to Philip Morris in Indonesian cigarette company 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 tax counsel to Altria in its approximately $50 billion spin-off of Kraft.
Served as Altria's tax counsel in Miller Brewing sale.
Acted as tax counsel for 3M in $1.2 billion Aearo acquisition.
Advised TE Connectivity stakeholders on tax matters resulting from domicile change.
Acted as special tax counsel to Altria in $1.5 billion debt offering.
Acted as special tax counsel to Altria in $200 million debt offering.
Acts as special tax counsel to PMI in debt offerings worth an aggregate $1.25 billion.
Advised Philip Morris in Colombian tobacco acquisition.
Served as U.S. tax counsel in PMI's US$2 billion amended and restated revolving credit facility.
Advised privately held conglomerate in connection with cost sharing arrangements and transfer pricing.
Advised multinational manufacturing and technology company in connection with audit of certain transfer pricing matters and availability and consequences of correlative adjustments.
Advised cable telecommunications company on cost sharing and transfer pricing arrangements in connection with international operations.
Advised multinational manufacturing and technology company on competent authority considerations relating to proposed IRS settlement.
Advised leading electronic commerce company and its subsidiaries in connection with global sales, procurement and contracting activities, including intercompany arrangements.
Advised an American paint manufacturer in connection with transfer pricing questions raised in audit and potential competent authority considerations.
Multimedia
Podcast: Likely impact of US tax reform on multinationals (December 13, 2018)
In this topical podcast, our global tax team discusses the likely impact the recent US tax reforms will have for multinationals. Join Ben Jones, Sebastiano Sciliberto, Marco Melisse, Torsti Lakari, ...
Webcast: Hot Topics in the Taxation of Private Investment Funds (March 13, 2013)
Sutherland Partners Robb Chase, Bob Copps and David Roby will address recent regulatory and legislative developments affecting the taxation of private investment funds. In particular, the program ...
Podcast: Taxes Turn: Legislative Proposals to Reform Taxation of Financial Instruments (January 31, 2013)
On January 24, 2013, the Chairman of the U.S. House Ways and Means Committee issued a discussion draft of proposed legislation that would reform the taxation of financial products, including debt ...
Podcast: Over the Hedge: Current Tax Considerations in the Structure and Operations of Hedge Funds and Other Private Funds (July 17, 2012)
Please join Sutherland's Private Funds Team for a webinar regarding current tax considerations in the structure and operation of hedge funds and other private funds. This program will provide an ...
News
“We are a firm that works to our strengths-particularly tax, insurance, SEC, regulatory and energy-and we are leaders in these fields.”
In the News
Taxing Digital Content and Cloud Computing: Implications of Proposed IRS Regulations (October 30, 2019)
Gartner
Eversheds Sutherland Partner Robert Chase II is featured in this Gartner article discussing the recently-proposed Internal Revenue Service (IRS) regulations designed to clarify the classification of ...
States, Int'l Gov'ts Can Lean On Each Other For Digital Taxes (August 27, 2019)
Law360
Eversheds Sutherland Partners Robb Chase and Michele Borens are quoted in this Law360 article discussing what digital taxation may look like and the work plan released by the Organization for ...
IRS Rules Threaten Broad Reach for Interest Deduction Cap (November 28, 2018)
Law360
Eversheds Sutherland Partner Robert Chase is quoted in this Law360 article discussing the recent Treasury and Internal Revenue Service (IRS) proposed regulations restricting deductions for interest ...
IRS, Treasury Float Rules on Foreign Earnings Under Tax Reform (August 2, 2018)
Compliance Week
Eversheds Sutherland Partner Robert Chase is quoted in this Compliance Week article discussing the proposed regulations focus on Section 965 of the Internal Revenue Code (IRS) as amended by the ...
Axing Deadwood Tax Regulations of Little Use to Businesses (February 15, 2018)
Law360
Eversheds Sutherland Partner Robert Chase is quoted in this Law360 article regarding the US Department of Treasury's regulatory review and its current proposal to cull nearly 300 outdated tax ...
Eversheds Sutherland Observations on the Unified Tax Framework (October 4, 2017)
Captive.com
Eversheds Sutherland’s legal alert, Big Six Releases Tax Framework: It’s Time to Get Dynamic, is featured in Captive.com.
Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities (March 2017)
Lexis Federal Tax Journal Quarterly
Eversheds Sutherland (US)’s legal alert, “Final Regulations Impose Reporting Obligations on Foreign-Owned Domestic Disregarded Entities,” is featured in the March 2017 edition of Lexis Federal Tax ...
Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes (June 2016)
Lexis Federal Tax Journal Quarterly
Sutherland’s legal alert, “Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes,” is featured in the June 2016 edition of Lexis Federal Tax Journal Quarterly.
Press Releases
Eversheds Sutherland Represents Cox Enterprises in Sale of Cox Media Group's Radio Station Portfolio (July 1, 2019)
ATLANTA - Eversheds Sutherland is pleased to announce that it represented Cox Enterprises on their agreement to sell Cox Media Group's Radio station portfolio as well as its CoxReps and Gamut ...
19 Eversheds Sutherland Practice Areas, 87 Attorneys Named Among Nation’s Best in 2019 Legal 500 United States (June 10, 2019)
Eversheds Sutherland is pleased to announce that 19 practice areas and 87 attorneys have been recognized in the 2019 edition of The Legal 500 United States, a comprehensive survey of legal service ...
Eversheds Sutherland Represents Cox Enterprises in Sale of Majority Stake in Cox Media Group Television Stations to Apollo Global Management (March 5, 2019)
Eversheds Sutherland is pleased to announce that it represented Cox Enterprises on their agreement with funds managed by Apollo Global Management, LLC (Apollo) to buy a majority interest in Cox Media ...
18 Eversheds Sutherland Practice Areas, 68 Attorneys Named Among Nation’s Best in 2018 Legal 500 United States (May 30, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 18 practice areas and 68 attorneys have been recognized in the 2018 edition of The Legal 500 United States, a comprehensive survey of legal ...
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 ...
16 Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2016 Legal 500 United States (June 16, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 16 practice areas and 59 attorneys have been ranked in the 2016 edition of The Legal 500 United States. Legal 500 is ...
14 Sutherland Practice Areas, 62 Attorneys Named Among Nation’s Best in 2015 Legal 500 United States (June 4, 2015)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 14 practice areas and 62 attorneys have been ranked in the 2015 edition of The Legal 500 United States, a ...
23 Sutherland Attorneys Named 2015 Washington, DC, Super Lawyers and Rising Stars (April 23, 2015)
WASHINGTON (April 23, 2015)-Sutherland Asbill & Brennan LLP today announced that 19 of the firm’s attorneys based in Washington, DC, have been selected as top attorneys in the state by Super ...
Challenge Accepted: Sutherland Offices Complete ALS Ice Bucket Challenge, Raise Funds for Charity (August 29, 2014)
ATLANTA, AUSTIN, HOUSTON, NEW YORK, SACRAMENTO and WASHINGTON-The Atlanta, Austin, Houston, New York, Sacramento and Washington offices of Sutherland Asbill & Brennan LLP recently accepted challenges ...
26 Sutherland Attorneys Named 2014 Washington, DC, Super Lawyers and Rising Stars (May 9, 2014)
WASHINGTON - Sutherland Asbill & Brennan LLP today announced that 20 of the firm’s attorneys based in Washington, DC, have been selected as top attorneys in the state by Super Lawyers. ...
Presentations
“The work is intellectually challenging, and our team approach-working closely with our colleagues in the firm and our clients-makes it interesting and exciting.”
Presentations
Final and Proposed Section 59A Regulations (December 4, 2019)
FBA Holiday BEAT
Eversheds Sutherland Partner Rob Chase presents Final and Proposed Section 59A Regulations at the FBA Holiday BEAT on December 4, 2019, in Washington, DC.
Tax, Trade, Tariffs, and the Supply Chain (November 21, 2019)
Philly CPE Day
Eversheds Sutherland Partner Robert Chase presents Tax, Trade, Tariffs, and the Supply Chain at Philly CPE Day, on November 21, 2019, in Malvern, Pennsylvania.
Brexit and emerging trends in the EU (November 21, 2019)
Philly CPE Day
Eversheds Sutherland Partners Ellen McElroy and Robert Chase spoke on a panel titled Brexit and emerging trends in the EU at Philly CPE Day, on November 21, 2019, in Malvern, Pennsylvania.
Methods to the Madness (November 19, 2019)
TEI Portland Chapter Seminar
Eversheds Sutherland Partners Robert Chase and Mary Monahan present “Methods to the Madness” at TEI Portland Chapter Seminar on November 19, 2019, in Portland, Oregon.
The New Worldwide Territoriality (November 19, 2019)
TEI Portland Chapter Seminar
Eversheds Sutherland Partners Robert Chase (US), Mary Monahan (US), Daniel Nicholas (US) and Ben Jones (International) present “The New Worldwide Territoriality” at TEI Portland Chapter Seminar on ...
M&A Strategies (November 5, 2019)
ACC Seattle
Eversheds Sutherland Partner Robert Chase presents M&A Strategies at ACC Seattle on November 5, 2019, in Seattle, Washington.
Managing International Tax Audit and Controversy in the Information Age (September 23, 2019)
AICPA & CIMA US Tax Update
Eversheds Sutherland Partner Robert Chase presents Managing International Tax Audit and Controversy in the Information Age at the AICPA & CIMA US Tax Update on September 23, 2019, in London, England.
The effects of digital taxation on tax certainty (September 19, 2019)
ITR Digital Taxation Conference
Eversheds Sutherland Partner Robert Chase presents The effects of digital taxation on tax certainty at the ITR Digital Taxation Conference on September 19, 2019, in London, England.
Decisions, Decisions: Tax Reform State Income Tax Filing Issues (June 25, 2019)
TEI Silicon Valley Federal Tax Day
Eversheds Sutherland Partner Robert Chase presents Decisions, Decisions: Tax Reform State Income Tax Filing Issues at the TEI Silicon Valley Federal Tax Day on June 25, 2019, in Silicon Valley, ...
Here Come the Locals - Increase in Aggressiveness of Local Taxing Authorities (June 25, 2019)
TEI Silicon Valley Federal Tax Day
Eversheds Sutherland Partner Robert Chase presents Here Come the Locals - Increase in Aggressiveness of Local Taxing Authorities at the TEI Silicon Valley Federal Tax Day on June 25, 2019, in ...
Publications
“We regularly advise multinational corporations on their cross-border transactions. This means working closely with trusted advisors in other jurisdictions to ensure the most efficient transaction structure from a U.S. and a local tax perspective.”
Legal Alerts
IRS issues final (for now) debt/equity regulations (May 15, 2020)
Final regulations addressing the treatment of certain related-party indebtedness as equity for US federal income tax purposes were released on May 13, 2020. The regulations finalize without material ...
Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies (April 29, 2020)
The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may ...
IRS releases Rev. Proc. 2020-22 enabling taxpayers to fully utilize changes made by the CARES Act to Section 163(j) (April 16, 2020)
On Friday, April 10, 2020, the IRS released Rev. Proc. 2020-221 providing procedural guidance to taxpayers wishing to implement changes made by the CARES Act to the section 163(j) business interest ...
Impermanent establishments, COVID-19, and the OECD’s response (April 8, 2020)
At the request of concerned countries, the Organisation for Economic Co-operation and Development (OECD) Secretariat has weighed in on tax considerations that are important both to businesses and ...
The CARES Act - Stimulating tax provisions (March 31, 2020)
On Wednesday, March 25, 2020, in response to the economic crisis caused by COVID-19, the United States Senate unanimously passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act. On ...
COVID-19 - tax considerations for US corporate taxpayers (March 17, 2020)
As COVID-19 continues to spread around the globe, companies and individuals are facing a diverse and challenging set of issues. These issues span a number of different contexts including tax, and ...
Changing the BEAT-Final regulations answer key questions, proposed regulations give new relief (December 12, 2019)
A year after the initial proposed BEAT regulations were released, Treasury and the IRS have issued a package of final and proposed regulations under 59A of the Internal Revenue Code of 1986, as ...
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 ...
Relief for REMICs addressing phaseout of LIBOR (October 11, 2019)
New proposed regulations provide guidelines for alterations to certain interests in real estate mortgage investment conduits (REMICs) and loans held by REMICs to take into account the anticipated ...
Articles
INSIGHT: IRS Response to Covid-19 and Tax Considerations for US Corporations (April 7, 2020)
Bloomberg Tax
As the coronavirus spreads, businesses and individuals are facing numerous challenges. In their article for Bloomberg Tax, Eversheds Sutherland attorneys Robb Chase, Mary Monahan and Brian Tschosik ...
Thinking Inside the Box: Tax Reform Proposals Consider “Patent” and “Innovation” Boxes (Summer 2015)
Partnering Perspectives
In their article for the Summer 2015 edition of Partnering Perspectives, Robb Chase and Taylor Kiessig explore the “patent box” or “innovation box,” which offers a significant reduction in U.S. tax ...
Tax Court Holds Rev. Proc. 99-32 Accounts Receivable Constitute Related-Party Indebtedness for Purposes Of 965 (December 13, 2013)
Tax Management International Journal
The United States Tax Court concluded that the taxpayer’s accounts receivable in BMC Software Inc. v. Commissioner, established between itself and its controlled foreign corporation pursuant to Rev. ...
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 ...
Economic Substance Directive: Some Substance, Many Questions (August 22, 2011)
Reposted with permission State Tax Notes
The FBAR Reset: Final Regulations Provide Mixed Guidance (April 25, 2011)
Tax Notes
Proposed Contingent Notional Principal Contract Regulations (Warning: Don’t Try This at Home) (2004)
Vol. 17, No. 5, Journal of Taxation and Regulation of Financial Institutions 36
Prevention of Mismatching of Interest and OID Deductions and Income Inclusions in Transactions with Related Foreign Persons (2004)
Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 P.L. 108-357, Vol. 45, No. 25, Tax Management Memorandum 563
Newsletters
Digital tax bytes - Weekly update (Week of May 18, 2020)
International news OECD Director predicts increased political focus on digital tax framework On May 21, OECD Tax Director Pascal Saint-Amans noted in a webcast that international finance ministers ...
Coronavirus: Tax Developments - Global (May 22, 2020)
Authorities across the globe are rapidly employing short-term protective measures against the economic impacts of COVID-19. The efforts include measures support businesses and their employees. Our ...
Digital tax bytes - Weekly update (May 19, 2020)
International news EU Commission to propose digital platform reporting rules in JulyAs EU member states begin to introduce rules to ensure proper taxation of sales and services provided through ...
Digital tax bytes - Weekly update (Week of May 4, 2020)
International news Kenya proposes 1.5% digital services taxOn May 6, Kenyan administrators presented their 2020 Finance Bill to Parliament. The Finance Bill includes a proposal to impose a 1.5% ...
Digital tax bytes - Weekly update (Week of April 27, 2020)
International news OECD Inclusive Framework postpones July meetings as compete political agreement may be delayed into 2021In a May 4 OECD-hosted webcast, Director Pascal Saint-Amans shared that ...
Digital tax bytes - Weekly update (Week of April 20, 2020)
International news OECD reaffirms year-end goal for digital tax agreementSpeaking at a virtual conference, Pascal Saint-Amans, the Director of the OECD Centre for Tax Policy and Administration, ...
Digital tax bytes - Weekly update (Week of April 13, 2020)
International news OECD releases report prioritizing digital economy taxationThe OECD released a report on April 15 which considers certain emergency tax and fiscal policies in response to the ...
Digital tax bytes-Weekly update (Week of April 6, 2020)
International news German Finance Minister urges continued digital tax work among COVID-19In a taped speech on fighting inequality though taxation, German Finance Minister Olaf Scholz emphasized ...
Digital tax bytes-Weekly update (Week of March 30, 2020)
International news Industry groups call for postponing OECD tax overhaul during coronavirus crisisIndustry groups including the United States Council for International Business, the Federation ...
Digital tax bytes-Weekly update (Week of March 23, 2020)
International newsIndia passes digital services tax and marketplace facilitator tax deducted at sourceIndia’s Finance Act 2020, which became law on March 27, 2020, contains two major ...
