Mr. 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.