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James R. Browne
Taxes, Estate Planning & Employee Benefits
Jim has more than 30 years of experience in the area of taxation, having served as lead counsel in matters involving federal, state, and foreign taxes. He advises clients on the U.S. income tax aspects of domestic and international business transactions. Mr. Browne has experience handling complicated tax and financing issues for a diverse range of clients in various industries, including healthcare, manufacturing, energy, real estate, and financial services.
Prior to joining Strasburger in 2005, Mr. Browne served as chief tax officer for several large publicly traded multinational companies, was a partner in a "Big 4" accounting firm, and was a partner in a nationally prominent law firm.
REPRESENTATIVE EXPERIENCE
- Advise sellers and purchasers on tax aspects of business acquisitions involving both strategic and financial purchasers, with transaction values ranging from $8 million to more than $30 billion.
- Prepare tax disclosures for debt and equity offering documents involving a variety of transactions, including oil and gas exploration and development, health care facility construction, real estate, securities trading and hedge funds, broadcasting, and alternative energy.
- Advise clients on tax aspects of reorganizations of corporate and partnership entities.
- Advise clients on tax and financing aspects of international operations, including structuring legal entities and intercompany agreements for foreign operations of U.S.-based clients; advising on U.S. and foreign tax considerations relevant to international assignments for domestic and foreign employees; structuring cross border business acquisitions and financing transactions; and advising non-U.S. clients on tax considerations and compliance requirements for U.S. operations.
- Special tax counsel to issuer on $450 million SEC registered offering of tax advantaged convertible notes.
- Advise SEC registered investment advisor (hedge fund) on tax aspects of derivative credit facility.
PUBLICATIONS AND PRESENTATIONSIns and Outs of Like Kind Exchanges, Presentation to North American Petroleum Accounting Conference, May 2010 (PDF)
Tax Aspects of Acquisitions and Dispositions of Oil and Gas Properties: Part II - Operating Businesses, Petroleum Accounting and Financial Management Journal, Spring 2010 (PDF)
Tax Aspects of Buying or Selling a Business, Presentation to Strasburger Transactional Academy, February 2010 (PDF)
Tax Aspects of Acquisitions and Dispositions of Oil and Gas Properties: Part I - Individual Properties, Petroleum Accounting and Financial Management Journal, Fall/Winter 2009 (PDF).
Transaction Tax Traps for the Unwary, Presentation to Dallas Bar Association Corporate Counsel Section, March 2009 (PDF) Real Estate Notes, Installment Sales, and Structured Sales, September 2008 (PDF)
Analysis of FIN 48 - Uncertain Tax Positions, BNA Accounting Policy and Practice, September 22, 2006 (PDF)
"Financial Reporting for Uncertain Tax Positions," Tax Notes, October 3, 2005 (PDF)
Tax Considerations in a Taxable Sale of Assets, March 2007 (PPT)
Choice of Entity, February 2007 (PPT)
The Texas Margin Tax on Business Entities, October 2006 (PPT)
An Alarming Trend in Financial Reporting for Loss Contingencies, May 2006 (PPT)
IN THE NEWS
Expert Q&A on Proposed Disclosure of Uncertain Tax Positions, Practical Law The Journal, March 2010
IRS Takes Pass on FIN 48 Data...for Now, by Tammy Whitehouse, Compliance Week, October 23, 2007 (Jim Browne quoted)
Rushing to punish private-equity firms with higher taxes could stifle entrepreneurship, by Jim Browne, Dallas Business Journal, July 27, 2007
CNBC "Morning Call", Strasburger Argues Against Raising the Tax on Private Equity Income, July 12, 2007
PROFESSIONAL AFFILIATIONSAdmitted, Texas, U.S. Tax Court Certified Public Accountant, Texas.
EDUCATIONVanderbilt University School of Law, J.D. (Order of the Coif) 1981 The University of Michigan, B.B.A. (Accounting), With Distinction, 1978
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