Devan Patrick is a US transactional tax partner in the firm's Corporate practice. He advises public and privately held companies, including private equity portfolio companies, as well as asset managers, investors, family-owned businesses, and other transaction participants on the US federal income tax aspects of domestic and cross-border business transactions.
Devan’s practice focuses on taxable and tax-free mergers and acquisitions, joint ventures, debt and equity offerings, and corporate and partnership restructurings. He advises foreign companies pursuing acquisitions, investments, and business operations in the United States, as well as US companies investing and conducting business abroad. His work includes structuring transactions involving corporations, partnerships, limited liability companies, and multinational ownership structures.
Devan advises asset management firms on the US tax considerations associated with developing and implementing investment products and tax-aware investment strategies. His work includes long-short separately managed account (SMA) strategies, tax-lot identification and liquidation planning, and related product structuring and operational tax considerations.
Devan also counsels US and international businesses on multijurisdictional disclosure and reporting regimes, including the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS), beneficial ownership reporting under the US Corporate Transparency Act for foreign entities registered to do business in the United States, and other mandatory disclosure regimes.
In addition to his business tax practice, Devan advises high-net-worth individuals, family offices, privately held businesses, trustees, and other fiduciaries on international private-client matters. He regularly handles pre-immigration and expatriation planning, cross-border trust and estate planning, private banking matters, foreign account reporting and voluntary disclosure, and other US federal and state tax compliance and regularization.