© 2016 The Texas Lawbook.
By Brooks Igo
(Aug. 2) – Locke Lord announced yesterday that tax expert Andrew Betaque has rejoined the firm as a partner in Dallas after working at Ernst & Young for a couple of years.
“Locke is in a sweet spot right now,” he said. “It’s a large, broad-based firm with a highly sophisticated transactional practice, while still retaining the drive, energy and growth potential not normally associated with such a large and established law firm.”
At EY, Betaque mostly handled projects focused on repatriation planning, post-acquisition integration and other types of cross-border transactions. He says his tenure at the global professional services firm “greatly enhanced” his cross-border tax experience.
Betaque says the hottest tax topic right now is the proposed regulations under Section 385, under which certain debt instruments can or will be recast as equity for federal income tax purposes. He says the proposed regulations are “the most significant development” in his career and that multinational corporations, private equity firms and certain S corporations need to pay close attention to the rules going forward.
“If finalized, they will upend decades of case law and IRS rulings relating to the debt/equity distinction,” he said. “The proposed regulations are extraordinarily complex and unclear in many respects, and they can lead to unintended and draconian tax consequences in many routine, non-abusive transactions.”
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