Michael Rodgers

Associate, Houston

Biography

Overview

Michael Rodgers is an associate in White & Case's Tax practice, and is resident in the Houston office. Michael, who specializes in cross-border tax planning, has focused on numerous tax-efficient structuring plans for a wide variety of public and private clients, including private equity funds and strategic buyers involved in both domestic and cross-border mergers, acquisitions, spinoffs, restructurings and other transactions. Additionally, he has assisted both individual clients and businesses with "inbound" issues, relating to the tax consequences and best practices associated with foreign investment and business activities in the United States, as well as "outbound" issues, involving Americans investing or doing business abroad.

Bars and Courts
Texas State Bar
US Tax Court
US District Court for the Southern District of Texas
Education
LLM
Taxation
New York University School of Law
JD
Arizona State University
BA
Government
Cornell University
Languages
English
Spanish
Dutch

Experience

Representation of numerous Fortune 100 multinational oil and gas companies in connection with proposed international tax legislation.*

Representation of a billion dollar private equity fund in connection with tax planning and structuring advice for various acquisitions of portfolio companies throughout Europe and South America.*

Representation of a global high-tech conglomerate in connection with tax planning, withholding tax, and debt financing considerations as a means to facilitate internal corporate restructuring.*

Representation as US tax counsel to a start-up Mexican company looking to expand operations into the United States in a tax-efficient manner.*

Representation of numerous US individual taxpayers with issues related to expatriation tax, residency analyses, and foreign bank account reporting obligations.*

Representation as US tax counsel of US citizens and small businesses investing in both Europe and Asia.*

Representation as US tax counsel of a mid-sized foreign fund engaged in commodities trading in the United States.*

Representation of a $200 billion global services fund engaged in tax equity investments involving renewable energy projects by providing international tax structuring advice and technical tax analysis. *

* Matters prior to joining White & Case

Publications

A Second Bite at the APA: Altera’s Rehearing and the Potential Invalidity of Cost-Sharing Regulations, Bloomberg BNA Tax Management International Journal, October, 2018

The Final §385 Regulations (Part II) – Classifying Interests in a Corporation, Bloomberg BNA Tax Management International Journal, February, 2017

The Final §385 Regulations (Part I) – Classifying Interests in a Corporation, Bloomberg BNA Tax Management International Journal, January, 2017

Proposed Regulations Under §385 – Classifying Interests in a Corporation, Bloomberg BNA Tax Management International Journal, July, 2016

Chomping at the Bit: U.S. Federal Income Taxation of Bitcoin Transactions, Journal of Taxation of Financial Products, Volume 11, Issue 3, 2013