Josiah Child focuses his practice on transactional tax matters. He advises businesses and high-net-worth individuals on a variety of domestic and international tax matters, including the tax aspects of:
- the formation and operation of joint ventures and portfolio company holding structures for U.S. and non-U.S. institutional investors and private equity funds;
- inbound investments in U.S. real property, including through REITs, for private investors, pension plans, and sovereign wealth funds;
- outbound investment by U.S. taxpayers through controlled foreign corporations, partnerships, and other vehicles;
- pre-immigration tax structuring for high-net-worth individuals planning to become U.S. residents;
- complex financing transactions for domestic and foreign investors and multinational financial institutions; and
- mergers and acquisitions by domestic and foreign investors, in public and private transactions.
Highlights
Mr. Child was a member of the University of Chicago Law Review. Prior to joining the firm, Mr. Child practiced at an international law firm in New York City.
Recent News
Click here for a full list of media coverage.
Speaking Engagements
Click here for a full list of speaking engagements.
Recent Publications
- "IRS Releases Final Carried Interest Regulations,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, January 14, 2021
- "IRS Issues Proposed Carried Interest Regulations,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, August 19, 2020
- "Final FDII/GILTI Regulations Withdraw Deduction Ordering Rule,"
with Jonathan S. Brenner, Caplin & Drysdale Client Alert, July 20, 2020
- "TAX PRACTICE: A Silver Linings Guidebook: Corporate Planning for Coronavirus Losses,"
with J. Clark Armitage and Elizabeth J. Stevens, Tax Notes Federal, May 18, 2020
- "SPECIAL REPORT: I'm Looking Through You, You're Not The Same: Partnership-Held CFCs,"
with Jonathan S. Brenner, Tax Notes Federal, October 7, 2019
- "Proposed Regulations Under Section 956,"
with H. David Rosenbloom and Jonathan S. Brenner, Caplin & Drysdale Client Alert, November 6, 2018
- "Navigating QBAI Quirks of the GILTI Regulations,"
with J. Clark Armitage and Jonathan S. Brenner, Bloomberg Tax, Tax Management International Journal, November 5, 2018
- "SPECIAL REPORT: The Nitty-Gritty of FDII,"
with Jonathan S. Brenner, Tax Notes, September 17, 2018
Click here for a full list of publications.