Marc D. Teitelbaum

Partner

Marc Teitelbaum is the chair of the Tax Department. Marc has been involved in advising public companies, underwriters and investment funds principally in the following areas:  acquisition and disposition of domestic and foreign corporations whether taxable or tax-free transactions; daily ongoing tax advice to public companies, regarding general corporate and consolidated return tax issues, including the U.S. tax consequences of foreign operations and foreign joint ventures, in particular, multi-national manufacturing and sales operations; debt and equity financings; investment strategies in partnership form including tax and accounting-advantaged structured domestic and cross-border financing arrangements; taxation of regulated investment companies; partnership taxation; and investment and trading funds.

Marc in recent years has provided tax advice with respect to in excess of one billion of tax advantaged cross-border corporate finance strategies and regularly advises banks concerning such matters. Marc has also been involved in advising on the formation of many private equity funds and offshore hedge funds, on tax issues that are attributable to their domestic and foreign activities, and deferred compensation arrangements for managers and their employees. He has also advised on several management company restructurings to achieve various goals and the sale of management companies.

Honors and Awards

• Ranked, Chambers USA, Tax, 2011 and previous years

Organizations

• Fellow, American College of Tax Counsel
• Member, The Tax Club
• Member, International Fiscal Association
• Member, Tax Section, New York State Bar Association
• Member, Tax Section, American Bar Association

Publications

• "A Disregarded Entity Must Be Taken Into Account," Tax Notes, Number 9, 2002
• "Compaq Computer Corp. and IES Industries Inc. Cases – The Empire Strikes Back," Derivatives Report, Number 4, 1999;  Tax Notes,  Number 6, 2000; and Tax Notes International, Number 7, 2000
• Letter to the Editor of Tax Notes concerning the Compaq Case, Tax Notes, Number 6, 1999
• "Canadian Exchangeable Share Transactions and Foreign Transaction Forms," Tax Notes International, Number 24, 1998; and Tax Notes, Number 10, 1998
• United States Report - Tax Developments YearBook (concerning the Inverworld decision), International Tax Review, and Euromoney, 1996 
• "The New Tax Benefit Entities: Qualified Small Business Corporations and Specialized Small Business Investment Companies," Journal of Corporate Taxation, 1994
• "Distributions of Partnership Refinancing Proceeds: Nonrecourse Cash Under the Section 704(b) Regulations,"  Journal of Partnership Taxation, 1988
• "The Impact on Partners of Allocations That Have Substantial Economic Effect," Journal of Partnership Taxation, 1987
•  "Foreign Ownership of Real Property in the United States in the 1980's," International Property Investment Journal, 1982

Presentations

• "Hedge Funds: Reality and Tax Reality," The Tax Club, New York, NY, March 2008
• "Proposed Tax Rules for Carried Interests," Financial Research Associates, LLC, November 2005, May 2006, November 2006, May 2007 and November 2007
• "Rethinking Hedge Fund Structures," New York State Society of CPAs, March 4, 2004
• "Taxation of Mezzanine Investing: Subordinated Debt and Warrants," New York Business Roundtable, Inc., February 24, 2004 
• "Disregarded Entity Must Be Taken Into Account," The Tax Club, New York City, October, 2002 
• "E-Commerce and Taxation - A Transactional Approach for a U.S. Multi-National Corporation," Tax Executive Institute, New York Chapter, March 23, 2000
• "Avoiding the Foreign Tax Credit Anti-Abuse Tests – Code Section 901(k), Notice 98-5 and the Compaq Case," ATLAS Foreign Tax Credit Update, November 8, 1999 and May 25, 2000, May 15, 2001, June 11, 2002, March 16, 2004, November 1, 2005
• "The President's Fiscal Year 2000 Budget Proposal," The Media Tax Club, New York City, March 1999
• "Canadian Exchangeable Share Transactions and Foreign Transaction Forms," The Tax Club, New York City, October 1998
• "Cross Border Financing Strategies," The Media Tax Club, New York City, September 1998
• "The New Section 1441 Regulations," The Media Tax Club, New York City, May 1998
• "Treasury Regulations under Code Section 894(c)," The Media Tax Club, New York City, November 1997
• "Certain Tax Aspects of Current Exchange Offers," New York University Conference on Mergers and Acquisition, May 1990
• "Section 704(b) Allocations," 45th and 46th New York University Annual Institutes on Federal Taxation, November 1986 and 1987
•  "Subchapter C Reform," 44th New York University Annual Institute on Federal Taxation, November 1985

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