Position

William McRae is a partner based in the New York office. Mr. McRae’s practice focuses on taxation and related matters, including structuring investments into the United States for non-US sovereign investors; the tax aspects of corporate acquisitions; the tax aspects of forming and investing in private equity funds, real estate funds and other investment vehicles; international tax planning for multinational corporate groups (FTC planning and repatriation strategies), tax aspects of restructurings (preservation and utilization of NOLs and other tax attributes, management of COD income); and the taxation of equity derivatives and other financial products. He also regularly publishes articles on Section 892 issues, and was a principal author of a June 2008 report by the New York State Bar Association Tax Section, “Report on the Tax Exemption for Foreign Sovereigns Under Section 892 of the Internal Revenue Code.”

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