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Robert A.N. Cudd

Robert A.N. Cudd
Senior Counsel
San Francisco, (415) 268-6904
New York, (212) 468-8026
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Education

  • Trinity College (B.A., 1968)
  • ;
  • University of Pennsylvania Law School (J.D., 1974)
  • ;
  • New York University School of Law (LL.M., 1978)

Practices

Federal Tax
Private Equity Investments + Buyouts
REITs

Bar Admissions

  • New York
  • California
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Application of the Self-Employment Tax and 3.8% Net Investment Income Tax to Fund Managers
3/6/2013
Federal Tax, Financial Institutions + Financial Services, Investment Management, Private Equity Funds, Private Equity Investments + Buyouts
Client Alert
American Taxpayer Relief Act of 2012: Extends Production Tax Credit for Wind and Many Other Cleantech Tax Incentives
1/4/2013
Cleantech, Environment + Energy
Client Alert
American Taxpayer Relief Act of 2012 Finally Settles Individual Federal Income Tax Rates for 2013 and Beyond
1/3/2013
Federal Tax
Client Alert
Reasserting Its Role as Final Interpreter of the Law, the Supreme Court Rejects IRS "Fighting Regulation" in United States v. Home Concrete & Supply, LLC, et al.
5/4/2012
Federal Tax
Client Alert
New Proposed Regulations Clarify Scope of Section 892 and Create De Minimis Exception for Inadvertent Commercial Activity
11/7/2011
Federal Tax
Client Alert
Section 355(d) - A New Approach to Writing Regulations
PLI Update
5/2011
Article
Treatment of Contingent Value Rights and Similar Instruments
M&A Forum
4/28/2011
Federal Tax
Article
Proposed Treasury Regulations Significantly Clarify and Expand Scope of “Publicly Traded” for Purposes of Determining the Issue Price of Debt Instruments
1/10/2011
Capital Markets, Debt Offerings + 144A Offerings, Federal Tax, Liability Management
Client Alert
Small Business Jobs Act of 2010 – Key Tax Incentive Provisions
9/28/2010
Federal Tax, Private Equity Funds
Client Alert
IRS Issues Proposed Rules Regarding Series LLCs and Cell Companies
9/15/2010
Federal Tax, Private Equity Funds
Client Alert
Integrity of the Voluntary Disclosure Program Confirmed
5/17/2010
Federal Tax
Client Alert
Therapeutic Tax Credit Rollout Anticipated for May 22, 2010
4/22/2010
Federal Tax, Life Sciences
Client Alert
Administration’s Fiscal Year 2011 Budget Reflects Significant Changes to Previous International Tax Proposals
2/3/2010
Federal Tax
Client Alert
Tax Update for Finance Lawyers
Financial Transactions Internal Update
12/2009
Federal Tax
Newsletter
Third-Party Purchaser's E&P Reduced by Interest on Loan Incurred to Acquire Life Insurance Policy
9/28/2009
Federal Tax
Client Alert
IRS Confirms the Application of a "Look-Through" Rule in Determining Whether the Risk Distribution Requirement is Satisfied for Reinsurance Companies
9/25/2009
Federal Tax
Client Alert
IRS: Loan Origination by Foreign Entity Through U.S. Intermediary Subject to U.S. Tax
9/25/2009
Federal Tax
Client Alert
Obama Administration Tax Proposal - Relevant Provisions for Private Equity and Other Investment Funds
5/19/2009
Banking + Financial Services, Corporate, Federal Tax Controversy, Private Equity Funds, Private Equity Investments + Buyouts
Client Alert
IRS Issues Rulings Addressing Secondary Market Transactions in Life Insurance
5/13/2009
Federal Tax Controversy
Client Alert
New Considerations in Debt Workouts under the American Recovery and Reinvestment Act of 2009
Journal of Taxation and Regulation of Financial Institutions, Vol. 22, No. 5
5/1/2009
Article
Drop in Stock Prices Inadvertently May Result in PFIC Classification for Publicly Traded Foreign Companies
4/2/2009
Corporate, Financial Institutions + Financial Services, Securities: Regulatory + Enforcement
Client Alert
Tax Considerations for Acquirers of Troubled Financial Companies
4/1/2009
Article
Stop Tax Haven Abuse Act - Tax Provisions of Interest to Private Funds and Fund Managers
3/13/2009
Banking + Financial Services, Corporate, Federal Tax Controversy, Private Equity Funds, Private Equity Investments + Buyouts
Client Alert
Temporary Deferral of Cancellation-of-Indebtedness Income Under the Recovery and Reinvestment Act of 2009
2/19/2009
Corporate
Client Alert
Summary of Cleantech Provisions in the Bailout Bill
10/3/2008
Cleantech, Environment + Energy, Federal Tax Controversy
Client Alert
New Proposed Legislation to Tax Income Derived From "Carried" Partnership Interests as Ordinary Income
6/27/2007
Banking + Financial Services, Corporate, Federal Tax Controversy, Investment Management, Private Equity Funds, Private Equity Investments + Buyouts, REITs
Client Alert
The Current Debate About the Federal Income Tax Treatment of "Carried" Interests - Status and Possible Approaches
4/13/2007
Banking + Financial Services, Corporate, Federal Tax Controversy, Private Equity Funds, Private Equity Investments + Buyouts
Client Alert
Section 409A - The New Tax Regime for Nonqualified Deferred Compensation Plans
11/29/2004
Article
Section 355 (d): A New Approach to Writing Regulations
7/12/1999
Article
Proposed Regulations Section 1.1001-3 (Modifications of Debt Instruments)
5/23/1999
Article
Federal Income Taxation of Certain Derivative Financial Products
5/20/1994
Article
Foreign Investors in U.S. Real Estate - Selected Tax Considerations
1/1/1985
Article
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