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Overview

"The effectiveness of tax counsel can be assessed by comparing time spent translating complexity against time spent creating it."

Bill has nearly two decades of experience on all aspects of business and transaction taxation including:

  • Partnership taxation (LLCs, Series LLCs, LPs, LLPs, GPs, safe-harbor and non-safe-harbor operating agreements, allocations and elections).
  • Corporate taxation (closely-held and publicly-traded corporations, mergers and acquisitions, divestitures, tax-free organizations, recapitalizations, spin-offs, split-ups, redemptions, S corporations, consolidated and affiliated groups, preservation and maintenance of tax attributes).
  • Taxation of real estate transactions (forward and reverse like kind-exchanges, joint ventures, TICs, REITs, foreign investment-FIRPTA)
  • Taxation of domestic and cross-border credit agreements and lending (drafting and negotiating tax provisions of LSTA and non-LSTA agreements and arrangements on behalf of lenders, borrowers and agents).
  • Taxation of financial produces and capital markets transactions (variable and fixed-rate trust-preferred securities, hybrid instruments, as well as traditional convertible, variable rate and contingent payment instruments).
  • Taxation of derivatives and hedging transactions (drafting and negotiating tax provisions of domestic and cross-border swaps, notional principal contracts and options, ISDA Master Agreements, schedules, confirmations and ancillary documentation).
  • Taxation of international transactions (income tax withholding and reporting, treaty application, controlled foreign corporations, passive foreign investment companies, inbound and outbound transactions).
  • Taxation of investment funds (including tax-related disclosures).
  • Taxation of restructurings, workouts and bankruptcies.
  • IRS private letter rulings.

Prior to joining Hirschler, Bill practiced at McGuireWoods LLP and Troutman Sanders LLP. In 2014, he left private practice to serve as interim president of a commercial real property operation in Northern Virginia.

Recognition

Named to “Legal Elite,” (Tax), Virginia Business, 2010, 2018

Selected for inclusion in Best Lawyers in America, Tax, Woodward/White, Inc., 2011-2013

Named a Virginia Super Lawyers “Rising Star,” Tax, Law & Politics Magazine, 2006, 2009-2011

Experience

Experience

  • Represented large (closely-held) S corporation in obtaining formal IRS letter ruling providing relief from potential termination of S corporation status resulting from accounting firm error affecting in-state shareholders.
  • Represented a group of converting S corporations holding substantially-appreciated (built-in-gain) real properties in securing five contemporaneous IRS letter rulings confirming “active” earnings and the inapplicability of the IRC Section 1375 “sting tax.”
  • Represented closely-held corporation in obtaining IRS letter ruling permitting its tax-free distribution of its timber farming operation under IRC Section 355.
  • Represented two publicly-traded energy companies in connection with various federal income tax aspects of billions of dollars in capital markets transactions and offerings.

Perspectives

Speaking Engagements

  • Bill Fendley is Co-panelist on Federal Income Tax Withholding Update-FACTA & Section 871(m) Practical Applications, Observations and Implications for Global Capital Markets, ABA Tax/Real Property/Trusts & Estates Joint Fall Meeting
    09.2012

Publications

Community

Community

Virginia State Bar, Former Chair and Former Member, Board of Governors, Taxation Section

American Bar Association, Former Member, Corporate Taxation, Partnership & LLCs, and Financial Transactions Committees

New York University School of Law, LL.M., Taxation

University of Dayton School of Law, J.D., cum laude

Emory & Henry College, B.A., cum laude, Dean’s List

  • Virginia
  • U.S. Tax Court
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