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Frank Ikonero Mugabi

Frank Ikonero Mugabi

Socio
His technical expertise is outstanding, which he balances with excellent pragmatism. He is very approachable and very responsive.
Chambers USA
About

Frank Mugabi is a partner in DLA Piper’s Tax Department and is based in New York. He has extensive experience in all areas of corporate taxation, both public and private-equity sponsored, including corporate mergers, acquisitions and dispositions, as well as corporate separations, reorganizations and workouts.  Frank’s corporate taxation experience has ranged from structuring and negotiating complex transactions, to internal pre-deal restructuring and planning in connection with the preservation and use of tax attributes.  Additionally, Frank advises on a wide range of international tax matters for clients in various industries, including repatriation planning, foreign tax credit planning, and Pillar 2 planning.

Frank is recognized by Chambers USA for his technical knowledge in a wide range of areas of the tax law. Similarly, Frank is recognized by Legal 500 USA for his experience in international tax matters and non-contentious tax matters.

Bar admissionsNueva York

NOTABLE TRANSACTIONS

  • Advised Loral Space & Communications in its inversion to Canada.
  • Advised Sony Music Entertainment in transactions involving acquisitions of music catalogues, as well as structuring payment arrangements with artists.
  • Advised Leonardo SpA in connection with the reorganization of its US operations.
  • Advised Adelphia Communications Corporation (ACC) on its liquidating Chapter 11 Plan (5th largest bankruptcy in the United States at the time of ACC’s bankruptcy filing).
  • Advised Solarwinds’ on its spin-off of its MSP business (N-able).
  • Advised Applera Corporation’s (Applied Biosystems) on its spinoff of Celera Genomics Group.
Education
  • LL.M., Harvard University 2003

     

    LL.B. (First Class Hons), Makerere University 2001

Awards

Chambers USA

  • Up and Coming, Tax: New York (2024)

The Legal 500 United States

  • Next Generation Partner, International Tax (2024)
  • Recommended, Financial Products (2022)
  • Recommended, International Tax (2017, 2019-2022) 
  • Recommended, US Taxes: Non-contentious (2018-2019, 2023-2024) 

PUBLICATIONS

  • "Tax Cuts and Jobs Act could have significant impact on structuring of US and foreign investments" (January 4, 2018)
  • "Copyright Act Section 203 Right of Termination – Assessing Potential Implications on Tax Characterization of Music Catalog Sales," NY Tax Club (January 2024)
  • "Disputed Ownership Funds: Making Sense of the 'Unused Attributes' Rule," Journal of Taxation, Vol. 131. No. 1 (July 2019)
  • "Recent Trends in Cross-Border Investments in Distressed Debt by U.S. Managed Hedge Funds," Journal of Taxation of Financial Products (Jan 1, 2006)

Seminars

  • Speaker, "Legal Mentor Transactional Bootcamp Series - Session 1," DLA Piper, 2023
  • Speaker, "Operational issues for federal including NOLs, excise tax, consolidated return rules, deductibility of deal costs, 409A, 280G," Tax Executives Institute NY Chapter – M&A Conference – June 8, 2023
  • Speaker, "Taxation of cryptocurrency and digital assets," Tax Executives Institute Region 9 Conference, April 2022
  • Speaker, "International M&A, Entity Rationalization Planning," Tax Executives Institute Region 9 Conference, April 2024

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