Robert is a partner in the New York office of Troutman Sanders LLP and is a member of the Firm’s Tax Practice Group. He advises clients on all aspects of corporate and partnership tax matters, with a particular emphasis on the tax aspects of private and public mergers, acquisitions, joint ventures, divestitures, private equity fund formation, financial products and electric and gas utility tax issues.
Representative Experience
Represented utility in connection with the negotiation of a Purchase and Sale Agreement for a 50 MW wind generation facility, in combination with a Power Purchase Agreement for the acquisition of the electrical output of a companion wind generation facility and related agreements governing the ownership and operation of certain shared Common Facilities
Represented investor in connection with the acquisition of the debt and equity associated with a 10 MW geothermal facility located in Nevada
Represented underwriters in connection with an investor owned utility's issuance of 70-year hybrid debt
Represented AbitibiBowater in connection with its issuance of $413 million in senior secured notes and its concurrent exchange offer for $293 million in senior unsecured notes
Represented Harman International Industries in its now terminated $8 billion sale to Kohlberg Kravis Roberts and GS Capital Partners
Represented Chaparral Steel Company in its $4.3 billion sale to Gerdau Ameristeel
Represented Bank of America in its sale of Marsico Capital Management to Thomas Marsico and its $3.3 billion purchase of U.S. Trust from The Charles Schwab Corporation
Represented Avery Dennison in its $1.34 billion merger with Paxar
Represented Morgans Hotel Group in connection with the creation of a joint venture with DLJ Merchant Bank, the financing to acquire, and the acquisition of, the Hard Rock Hotel & Casino in Las Vegas
Represented Sky Financial Group Inc. in its merger with Huntington Bancshares Incorporated
Represented private equity fund sponsors in the formation of new funds
Represented Citizens Banking Corporation in its issuance of 60-year hybrid debt
Represented Comerica in its issuance of 80-year hybrid debt
Presentations and Speaking Engagements
Speaker, Significant Cases and Rulings, Meeting of the Energy Tax Council - October 2009
Speaker, Financing Incentives, Meeting of the Energy Tax Council - April 2009
Speaker, Financing Incentives, March 2009, Troutman Sanders Seminar on Energy Support in the Stimulus Bill - March 2009
Co-Presenter, Circular 230, The Higher Cost of "Putting It In Writing”, Edison Electric Institute Semi-Annual Tax Committee Meeting - June 2005
Co-Presenter, An Analysis of the Long Term Capital Cases, Edison Electric Institute Semi-Annual Tax Committee Meeting - November 2004
Speaker, Tax Legislative Update for Owners of Nuclear Power Plants, Nuclear Decommissioning Fund Study Group - May 2003
Co-Presenter, Regulatory v. Tax Accounting - Distinctions, Differences and Common Ground, ABA Section of Taxation, Tax Accounting Committee -Fall 2002
Speaker, Tax Legislative Update for Owners of Nuclear Power Plants, Nuclear Decommissioning Fund Study Group - May 2002
Co-Presenter, Transaction Variations in the Market and Tax Planning, IMI Nuclear Decommissioning Trust Forum - November 2001
Speaker, The Ramifications of NRC License Extensions for Nuclear Power Plants, IMI Nuclear Decommissioning Trust Forum - November 2001
Speaker, Tax Planning Opportunities with Respect to Purchases of Nuclear Power Plants, Nuclear Decommissioning Fund Study Group - May 2001
Publications
Are Investment Unit Contract Adjustment Payments Ordinary Income?, Journal of Taxation of Financial Products, Vol. 6, No. 1 (2006)
Co-Author, Musings on the 'Active Business Requirement ', Tax Analysts, Special Report Tax Notes, Vol. 98, No. 8, February 17, 2003
Continuing Tax Uncertainties Surround the Trading of C02 Emission Allowances, Journal of Taxation of Financial Products (Summer 2001)
Contributing author, Financial Products: Taxation, Regulation, and Design, Andrea S. Kramer, 2000 Supplement
1996 West Virginia Tax Developments, State and Local Tax Lawyer (Vol. 2, 1997)