Rishi Sodhi

Practice Areas

Corporate, Employee Benefits & Executive Compensation, Insurance, Insurance Taxation, Taxation, Transactions

Industry Sector Expertise

Energy & Infrastructure, Health Care & Life Sciences, Innovative Technology, Manufacturing

Experience

Representative Experience*

Transactional Tax Matters

Publicly traded global medical technology company’s US$1.025bn acquisition of a portfolio audio company.

North American logistics company’s acquisition of an intermodal drayage and warehousing services company.

Telecommunication technology company’s acquisitions of a data security platform company and a Latin American A2P and enterprise messaging company.

Publicly traded partnership conversion into a subchapter C corporation via “check the box” election.

Combination of two publicly traded gaming companies.

U.S. private equity fund’s acquisition of a global security integrator.

U.S. private equity fund’s acquisition of a global golf and club management company.

U.S. private equity fund’s US$1.5bn carve-out acquisition of a global enterprise software business.

U.S. private equity fund’s sale of a subscription based promotional, advertising and e-commerce intelligence solutions company.

Fortune 500 company’s US$2.3bn acquisition of an identity theft protection company.

Publicly traded digital entertainment company’s US$1.1bn acquisition of a DVR manufacturer.

Tax Insurance Matters

Rishi has assisted in the assessment and underwriting of a wide range of tax risks, including but not limited to the following:

Tax-free reorganizations/Section 355 spinoffs

Internal restructurings (U.S. and foreign)

S corporation issues

Tax credits (ITCs, PTCs and ERCs)

Subchapter K/partnership tax matters (disguised sales, mixing bowl transactions, liquidations, allocations)

U.S. state and local tax matters (credits, grants, revaluations, nexus, sales tax, exemptions)

U.S. international tax matters (Subpart F, Section 367, Section 965 transition tax, GILTI, FDII, BEAT, Section 163(j), Section 7874/inversions)

Foreign tax matters (PE, withholding tax, treaty qualification, substance, country-specific issues)

Transfer pricing

Income characterization (CG v. OI)

Worthless stock/bad debt deductions

Debt v. equity characterization

Amortization/anti-churning

Rescission doctrine

Employee benefit tax matters (employee classification, Section 280G, Section 83(b) elections, retirement plans)

Trust and estate planning tax matters

Transfer taxes (U.S. state and local, and foreign)

*Certain of these matters were handled prior to joining Foley.

Education