Bryan Smith
Bryan Smith

Bryan Smith

Partner

Seattle

206.359.6740
bryan.smith@ashurstperkins.com

Introduction

Bryan represents clients in complex financial matters, with a focus on federal income tax.

Bryan S. Smith has experience in many aspects of federal income tax, including M&A deals, international and cross-border transactions, executive compensation, public and private offerings, joint ventures, real estate investment trusts, real estate and leasing transactions, and federal tax controversies. 

Education & credentials

  • Seattle University School of Law, J.D., magna cum laude, Research & Technical Editor, Seattle University Law Review, 1995
  • Seattle Pacific University, B.A., 1992
  • Washington
  • Deloitte & Touche L.L.P., Seattle, WA, Manager, Tax Department, 1995-2000
  • Eisenhower & Carlson, Tacoma, WA, Rule 9 Intern and Summer Associate, 1994-1995
  • Connolly, Holm, Tacon & Meserve, Olympia, WA, Summer Associate, 1993-1994

Professional recognition

  • Named "Lawyer of the Year," for Tax Law by Best Lawyers in America, 2020, 2024, 2026

  • Listed in Best Lawyers in America: Tax Law, 2013-2026

  • Listed in Chambers USA "American's Leading Lawyers" for Tax, 2007, 2019-2026

  • Listed in Washington Law & Politics, "Rising Stars of Washington Law," 2008

Acquisitions and Restructuring

$150 million acquisition of U.S. corporation with substantial European operations, and related restructuring; development and negotiation of tax-efficient structure for substantial investment by private equity fund in professional corporation.

Executive Compensation

Structuring of tax-efficient LLC equity plans; analysis and negotiation of golden parachute tax provisions of employment contracts and acquisition documents; analysis of issues relating to incentive and nonqualified stock options and other compensation arrangements.

International Transactions

$300 million acquisition of Canadian corporation by U.S. corporation; restructuring of foreign corporation to avoid status as a passive foreign investment company in connection with securities offering.

Palomar Capital Advisors Ltd. Investment in Mantacor Energy LLC

Represented Palomar Capital Advisors Ltd., a private equity firm based in Zurich, Switzerland, in connection with its initial US$15 million investment in Mantacor Energy LLC, an oil and gas exploration and production company focused on the D-J (Denver-Julesburg) Basin of Colorado and the San Juan Basin in New Mexico.

REIT Representation

Representation of a large REIT with significant European operations, including analysis of foreign acquisitions, joint ventures and intercompany transactions; development and negotiation of complex private REIT structures; REIT counsel in connection with sale of public REIT for total consideration in excess of $3 billion.

Representation Before IRS

Successful defense of taxpayer against IRS assertion of tax liability in excess of $200 million.

Subsidiary Sale

Sale of corporate subsidiary for consideration in excess of $1 billion in a transaction governed by Section 338(h)(10).

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