Robert Cudd is a partner practicing in the San Francisco and New York offices of Morrison & Foerster. Mr. Cudd has over 30 years' experience in a broad range of domestic and foreign tax matters involving corporations, partnerships and intangible property such as patents and licenses.
Mr. Cudd has had extensive experience structuring all types of corporate and partnership transactions, including those involving foreign entities, limited liability companies, public and private REITs and tax-exempt organizations such as pension funds and foundations. He has been involved in all of the tax aspects of structuring investments in real estate, securities, joint-venture projects, private equity funds and hedge funds. He has broad experience in taxable and tax-free corporate, partnership, reorganizations of distressed entities in and outside of bankruptcy; in business acquisitions and dispositions; and in structuring complex debt arrangements.
Mr. Cudd has structured numerous cross-border arrangements including structuring licensing arrangements and other arrangements for domestic and foreign corporations and partnerships for both U.S. and foreign investors. These transactions included both inbound and outbound transfers or deemed transfers of technology. Recent reorganization and merger transactions involving large capitalization corporations include Intel, VMware and Clorox.
Mr. Cudd is admitted to practice in the state courts of New York and California, the Federal Court for the Southern District of New York, the 2nd Circuit U.S. Court of Appeals and the United States Supreme Court. He is also listed among New York Super Lawyers for 2011.
Prior to joining Morrison & Foerster, Mr. Cudd was a partner in the New York office of Dewey & LeBoeuf.
Mr. Cudd received his B.A. from Trinity College in 1968, where he was a member of Phi Beta Kappa, his J.D. from the University of Pennsylvania in 1974 and his LL.M. in Taxation from New York University in 1978.