Richard L. Reinhold
Willkie Farr & Gallagher LLP
787 Seventh Avenue
New York, N.Y. 10019-6099, U.S.A.
Richard L. Reinhold is a partner and Chair of Willkie’s Tax Department in New York. Mr. Reinhold’s practice includes domestic and international business tax matters relative to mergers and acquisitions, joint ventures, investment funds, corporate restructurings, and financing transactions.
Chambers USA (2014) ranks Mr. Reinhold among the leading individuals practicing Tax Law in New York. He has also been recognized in The Best Lawyers in America,Who's Who Legal, Euromoney Guide to the World’s Leading Tax Lawyers, and New York magazine’s "Best Lawyers in New York."
Selected Professional and Business Activities
Mr. Reinhold is a former Chair of the New York State Bar Association (Tax Section) and has been a member of its Executive Committee since 1985. He is a Fellow of the American College of Tax Counsel, a member of the Board of Advisors of the New York University School of Law International Tax Program, and a member of the Tax Forum and Tax Club.
Mr. Reinhold is an Adjunct Professor of Law at the New York University School of Law. Additionally, he has lectured and written widely on federal income tax matters.
Selected Significant Matters
Tranche C Lenders in the $3.25 billion credit bid for, and restructuring of Delphi Corporation
Colony Capital LLC in Fertitta Colony Partners LLC’s $8.8 billion acquisition of Station Casinos, Inc.
AlixPartners LLC and its founder in the sale of a majority stake to Hellman & Friedman LLC as part of a recapitalization
Teva Pharmaceutical’s $7.4 billion acquisition of IVAX Corp.
Colony Capital in its acquisition (with Kingdom Hotels International) of Fairmont Hotels & Resorts Inc. in a deal valued at $5.5 billion, and the combination with the Raffles hotel portfolio
Carlos Slim’s and Affiliated Entities sale of 13% block of MCI Corp. to Verizon Corporation
Representation of Donald J. Trump in bankruptcy restructuring of Trump Hotels and Casino Resorts
National Energy & Gas Transmission bankruptcy
Adelphia Communications Corp. bankruptcy
Fortress Investment Group LLC $1.2 billion acquisition of the consumer lending arm of Conseco Finance
Zurich - Converium IPO - Restructuring of Zurich Re's reinsurance operations into Converium AG in conjunction with an IPO by that company
Zurich - Farmers Group - RegCaPS - Offering of $1.125 billion of hybrid securities designed to provide subordinated capital
Zurich - ECAPS - Offering of $1.7 billion of hybrid securities
Selected Publications and Lectures
"What NatWest Tells Us About Tax Treaty Interpretation," 119 Tax Notes 169 (April 14, 2008)
“Some Things That Multilateral Tax Treaties Might Usefully Do,” 57 Tax Lawyer 661 (2004)
"What is Tax Treaty Abuse? (Is Treaty Shopping an Outdated Concept?)," 53 Tax Lawyer 663 (2000)
"Section 355(e): How We Got Here and Where We Are," 82 Tax Notes 1485 (March 8, 1999)
"Issues and Strategies in Corporate Financings and Refinancings" (with A. Solomon), 11 Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings 9 (PLI 2000)
"Contingent Liabilities and Contingent Purchase Price in Taxable Asset Acquisitions and Section 338(h)(10) Transactions," 53 N.Y.U. Annual Institute on Federal Taxation Sec. 13 (1995)
"Tax Issues in Equity Swap Transactions," 57 Tax Notes 1185 (November 23, 1992)
"Spin-Offs and Other Dispositions of Unwanted Assets in the Context of Acquisitions," 47 N.Y.U. Annual Institute on Federal Taxation Sec. 50 (1989)
Contributing Author, Federal Income Taxation of Debt Instruments (4th ed. 2000)
1976, SUNY at Buffalo Law School, J.D.
1973, Cornell University, A.B.
New York, 1977
- United States District Court, Western District of New York, 1977
- United States Tax Court, 1978