- Advising insurance companies and managing general agents regarding coverage for specified tax risks including those related to S corporations, renewable energy tax credits, and various M&A transaction issues.
- Advising clients on federal tax issues arising from the coronavirus pandemic, including the tax impact of new federal legislation designed to mitigate the economic effects, business disruption issues, and tax considerations for insolvent and troubled businesses.
- Representing a publicly traded company protesting an $18 million IRS disallowance of bad debt expense deductions and $60 million of partnership basis.
- Represented Total System Services (TSYS) in its $1.05 billion acquisition of Cayan, a payment technology company with operations in the U.S. and Northern Ireland.
- Advised Synovus Financial Corp. in its $2.9 billion acquisition of FCB Financial Holdings.
- Represented LinQuest Corporation, a federal government contractor and leading provider of space systems technology solutions to the U.S. defense and intelligence communities, in the sale of a controlling interest to Madison Dearborn Partners and CoVant Management.
- Represented a pharmaceutical distribution company in a taxable spin-off and sale of one of its major business lines for $335 million.
- Advised Synovus Financial Corp. on a $350 million preferred stock offering.
- Represented a publicly traded company protesting a $12 million IRS disallowance of research and experimentation (R&E) credits and obtained an 80 percent IRS concession.
- Represented multiple clients and assisted with the preparation of disclosures of foreign bank accounts and assets through the IRS’s Offshore Voluntary Disclosure Program (OVDP).
Associate,
- Phone: 404.881.7836
- Email: seth.buchwald@alston.com
Drawing from his experience as a certified public accountant, Seth guides his clients through complex business transactions and controversy matters.