William R. Skinner
650-335-7669
wrskinner@fenwick.com
Partner
Tax
William R. Skinner
William R. Skinner
William R. Skinner
Partner
Tax

Will Skinner focuses on structuring and planning for corporate transactions, corporate restructurings, and international tax planning. He blends deep technical analysis with practical advice, and brings a breadth of knowledge of different tax areas. In his 15 years of tax practice, Will has significant experience with tax controversies at the audit, IRS Appeals, and litigation levels, which informs his perspective in developing defensible tax planning approaches.

Prior to entering private practice, Will clerked for the Honorable Carlos T. Bea, on the Ninth Circuit Court of Appeals. He writes and speaks regularly on international and corporate tax topics, and teaches outbound international taxation at the MST program of San Jose State University.

  • Planning for tax-sensitive corporate transactions, including multi-billion dollar tax-free reorganizations, tax-free spin-offs (including Reverse Morris Trust transactions), foreign / US business combinations, “double dummy” transaction, partnership M&A and private equity transactions.
  • Restructuring corporate holding companies, IP ownership and group financing companies for outbound and inbound companies.
  • Optimization of use of NOLs, foreign tax credits and other tax attributes, and planning for insolvent subsidiaries.
  • Financial products, such as prepaid forward contracts, crypto transactions, and marketplace lending and currency hedging / Treasury center activities.

  • Planning for tax-sensitive corporate transactions, including multi-billion dollar tax-free reorganizations, tax-free spin-offs (including Reverse Morris Trust transactions), foreign / US business combinations, “double dummy” transaction, partnership M&A and private equity transactions.
  • Restructuring corporate holding companies, IP ownership and group financing companies for outbound and inbound companies.
  • Optimization of use of NOLs, foreign tax credits and other tax attributes, and planning for insolvent subsidiaries.
  • Financial products, such as prepaid forward contracts, crypto transactions, and marketplace lending and currency hedging / Treasury center activities.

  • RIA Checkpoint Catalyst, “Corporate Separations and Divisions Involving Foreign Corporations”
  • “Assumed Contingent Liabilities in Asset Acquisitions,” Journal of Corporate Tax’n June 2022
  • “Impact of Tax Reform on Purchase and Sale of Controlled Foreign Corporations,” BBNA International Journal 2018
  • “Pre-Liquidation Dividends,” Journal of Corporate Taxation 2013
  • “Contingent Value Rights,” Journal of Taxation 2009 (selected for publication in PLI in corporate tax practice series)

  • RIA Checkpoint Catalyst, “Corporate Separations and Divisions Involving Foreign Corporations”
  • “Assumed Contingent Liabilities in Asset Acquisitions,” Journal of Corporate Tax’n June 2022
  • “Impact of Tax Reform on Purchase and Sale of Controlled Foreign Corporations,” BBNA International Journal 2018
  • “Pre-Liquidation Dividends,” Journal of Corporate Taxation 2013
  • “Contingent Value Rights,” Journal of Taxation 2009 (selected for publication in PLI in corporate tax practice series)

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