Bio

Eric Udowychenko brings a particular proficiency in M&A and tax services to the Gibbons Corporate Group. His experience includes leading buy-side and sell-side clients through international, federal, state, local, and transfer-pricing tax issues, conducting tax due diligence, structuring, and performing integration services for acquisitions of both U.S. and non-U.S. companies, including for deals exceeding $450 million. Mr. Udowychenko is well-versed in conducting tax due diligence and tax structuring services for private equity and strategic clients acquiring stock or assets of U.S. and non-U.S. businesses, especially in the software space. He assists in performing tax due diligence for inbound and outbound transactions, analyzing various tax issues such as sales tax, check-the-box rules, successor liability, the portfolio interest exemption, withholding taxes, permanent establishments, tax treaties qualifications, anti-churning, debt-equity classifications, foreign tax credits, and more. He is well-versed in modeling tax attributes and financial modeling (ability to utilize tax NOLs, R&D credits, bonus depreciation, etc.) and is skilled in drafting stock and asset acquisition agreements, disclosure schedules, Section 1060 allocations, and investment fund agreements. He has also written memoranda on such topics as foreign tax credits, the tax treatment of legal settlements, qualified small business stock, transaction costs, deferred compensation, investment tax credits, up-C transactions, anti-churning issues, and more. Additionally, he analyzed proposed and final Treasury Department regulations to evaluate impacts on clients’ transactions, and optimized the location of intellectual property and considered the effect of Section 901 on foreign tax credits for licensing intellectual property.