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J. Tyler Moser

Associate
Pittsburgh
+1.412.355.6709
Fax +1.412.355.6501
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Primary Practice

Secondary Practices

Education

  • LL.M., New York University School of Law, 2014, (Taxation)
  • J.D., University of Maryland School of Law, 2012, (magna cum laude; Order of the Coif; Managing Editor, Journal of Legislation and Public Policy)
  • B.S.B.A., Shippensburg University, 2006

Admissions

  • Bar of District of Columbia
  • Bar of Maryland
  • Bar of Pennsylvania
  • United States Tax Court
  • Overview
  • Additional Background
  • Representative Work
Tyler Moser advises clients on a broad range of U.S. federal, state and international tax issues in connection with public and private mergers and acquisitions, restructurings, fund formation, debt and equity financing, information reporting compliance and tax aspects of complex business transactions. Mr. Moser has extensive experience with renewable energy investments, the partnership audit rules, and compliance issues pertaining to ownership of offshore financial assets, the Foreign Account Tax Compliance Act (“FATCA”) and the Foreign Investment in Real Property Tax Act (“FIRPTA”).

A portion of Mr. Moser’s practice involves counseling tax-exempt organizations with respect to tax planning, governance, unrelated business income tax issues, and charitable giving. In addition, he represents individuals and businesses in tax controversies before the Internal Revenue Service and state and local taxing authorities.

Professional Background

Prior to joining the firm, Mr. Moser served as a law clerk to the Honorable Robert P. Ruwe on the United States Tax Court in Washington, D.C. from 2014 to 2017. From 2012 to 2013, he was a law clerk to the Honorable Patrick L. Woodward on the Maryland Court of Special Appeals.

Professional/Civic Activities

  • Allegheny County Bar Association, Tax Section
  • American Bar Association, Tax Section
Mergers and Acquisitions
  • Represented a publicly-traded engineered materials company in its US$3.2 billion synergistic acquisition of another publicly-traded company and related credit facility amendment.
  • Represented TandemLife, a privately-held medical device company focused on advanced cardiopulmonary temporary support solutions, in connection with its sale to LivaNova, PLC, for US$250 million.
  • Represented WesBanco, Inc., a public financial services company, in its US$378.2 million cash and stock acquisition of Farmers Capital Bank Corporation.
  • Represented a publicly-traded chemicals and materials company in its US$200 million cash acquisition of a competitor.
  • Represented Jvion, Inc., a private company engaged in healthcare artificial intelligence, in connection with a US$95 million growth equity investment by JMI Equity.
Securities and Capital Markets
  • Represented a pubic company in an aggregate US$1 billion underwritten public offering of senior notes.
  • Represented a publicly-traded molecular diagnostics company focused on colorectal cancer screening technology in a US$600 million underwritten public offering of convertible senior notes and related exchange offer.
  • Represented Duquesne Light Holdings, Inc., in a US$325 million offering of senior notes exempt from registration under the Securities Act in accordance with Rule 144A.
  • Represented a specialty metals company in a US$408 million underwritten public offering of common stock and related US$350 million redemption of a series of outstanding senior notes.
Energy Investment
  • Represented a real estate and financial services company in connection with the structuring of a renewable energy tax equity fund.
  • Advised an ESOP-owned subchapter S corporation in connection with the structuring of renewable energy partnership investments.
  • Advised various private renewable energy companies in connection with investment in wind energy facilities and qualification for tax credit incentives, including compliance with Internal Revenue Service safe harbors.
Tax-Exempt Organizations
  • Advised a university-based healthcare system in connection with the licensing of electronic health records software to a private physicians’ group.
  • Advised various tax-exempt charitable organizations in connection with the implementation of remote employment programs and associated state and local tax implications.
  • Advised various individuals and tax-exempt organizations in connection with formation, acquisition and restructuring and issues related to governance, unrelated business income tax and dissolution.
Miscellaneous
  • Advised various clients on tax issues pertaining to structured settlements, including both qualified settlement funds under Internal Revenue Code Section 468B and non-qualified assignments of settlement obligations.
  • Advised a real estate fund manager on tax implications and potential strategies related to the formation and operation of a captive insurance company.
  • Represented a public shipping company in negotiating and structuring a bare boat charter agreement and associated financing arrangements.
  • Advised various individuals in connection with compliance issues pertaining to ownership and reporting of offshore financial assets (including FinCEN Form 114 or “FBAR”).
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