Seth M. Buchwald

• 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).

Seth Buchwald is an associate in the Federal & International Tax Group. He uses his experience as a former certified public accountant (CPA) to understand and assist U.S. and multinational clients on planning and compliance with domestic and international tax issues, including M&A, civil and criminal tax controversy, and international corporate restructurings. Seth also has extensive experience advising insurance companies and managing agents in coverage for specified tax risks in M&A and other transactions, such as those involving renewable energy tax credits. He has worked extensively with various provisions of the Coronavirus Aid, Relief, and Economic Security Act and the Tax Cuts and Jobs Act, including Employee Retention Tax Credits, the Section 965 transition tax, global intangible low-taxed income (GILTI), and Section 962 elections.

Before joining Alston & Bird, Seth gained experience interning for the Hon. Tony M. Davis of the U.S. Bankruptcy Court for the Western District of Texas and the global energy transaction group of a major Houston law firm. He also interned for a small Houston tax-focused boutique firm, advising high-net-worth individuals on tax matters. As a former CPA, he gained a variety of experiences working in external and internal audits and tax compliance.

Bar Admissions

• Georgia

Education

• University of Texas at Austin (J.D., 2017)
• University of Georgia (B.B.A., 2011)

Memberships