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Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery LLP based in the Chicago office. He is a member of the Tax Department and co-chairs the International Tax Practice Group.
Lowell’s practice focuses on international tax planning for multinational companies. He handles cross-border acquisitions, dispositions, mergers, reorganizations, joint ventures, leases and financings. He advises concerning multi-jurisdictional business structures and the use of special purpose foreign entities. He also works extensively with a network of foreign lawyers in over 50 countries on developing structures that minimize foreign taxes of U.S. multinationals without adversely affecting their U.S. tax position. Lowell was listed in the latest, as well as previous editions of Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business, The Best Lawyers in America, The International Who's Who Of Corporate Tax Lawyers, The International Who's Who of Business Lawyers, Who’s Who Legal: Illinois, and Euromoney’s Guide to the World’s Leading Tax Advisors. Lowell has also been named an Illinois Super Lawyer by Law & Politics.
Lowell is a frequent lecturer. He has spoken on a variety of international topics for the Tax Executives Institute, American Bar Association, The University of Chicago Law School’s Annual Federal Tax Conference, International Bar Association, GWU Annual Institute on International Taxation, Chicago Tax Club, Practising Law Institute, BNA Tax Management Advisory Board and the International Fiscal Association. Lowell is an Adjunct Professor at the Northwestern University School of Law, where he teaches Advanced International Taxation.
Lowell is the editor-in-chief of CCH’s International Tax Journal and has authored four BNA portfolios on the tax treatment of U.S. controlled foreign corporations: 926 TM, Subpart F General; 927 TM, CFCs Foreign Personal Holding Company Income; 928 TM, CFCs Subpart F-Foreign Base Company Income and 930 TM, Subpart F-Sections 959-964, 1248 and Related Provisions. Lowell has published numerous articles on international topics. Recent articles include, Pre-Sale Branch Election for CFC Target: Dover v. Comr. Says No Subpart F Income, (TMIJ, August 13, 2004), "Practical Applications of the CFC Look-Thru Rule Under Notice 2007-9," (TMIJ, June 8, 2007), "Code Sec. 338(g) Election Applied to Foreign Targets: Permissible Tax Arbitrage," (ITJ, May-June 2007), "International Planning Using Code Sec. 304(a)(1)," (ITJ, July-August 2007), "Application of Subpart F to Gain Derived By a CFC From The Sale of a Business: Form Matters," (TMIJ, August 10, 2007).
Lowell is an active member of International Committees and Advisory Boards. He co-chairs an International Tax Roundtable group that includes tax lawyers from the major European countries and meets twice a year to discuss significant cross-border topics. He is a fellow of the American College of Tax Counsel, and chairs the ABA Subcommittee for Controlled Foreign Corporations, PFICs and contract manufacturing. Lowell is also a member of the Planning Committee for the University of Chicago Law School’s Annual Federal Tax Conference; he is a member of the ABA Committee on Foreign Activities of U.S. Taxpayers, and is a member of the Advisory Board of the GWU Annual Institute on International Taxation. In addition, he also is a member of the Tax Management International Journal’s Advisory Board, the Tax Management Advisory Board Foreign Income, and the Board of Advisors of the International Tax Journal.
Education
University of Illinois College of Law, J.D. (magna cum laude), 1982
University of Illinois at Urbana-Champaign, B.S. (highest distinction), 1979 |
