Josiah Child

Josiah Child’s practice is focused 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 (CFCs), 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

• Caplin & Drysdale Names Josiah Child Of Counsel to the Firm, April 1, 2021
• 10 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Midyear Meeting, January 3, 2019
• Caplin & Drysdale Welcomes Josiah Child to Its New York Office, February 20, 2018

Click here for a full list of media coverage.

Speaking Engagements

• Panelist, Getting Out of GILTI: The High-Tax Exclusion Election, AICPA & CIMA U.S. Tax Update Conference, November 23, 2020
• Moderator, 360 Degree Perspective: U.S. Withholding and Global Information Reporting, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 17, 2019

Click here for a full list of speaking engagements.

Recent Publications

• "Wouldn't It Be Nice: Reimagining US Taxation of Outbound Investment," with Jonathan S. Brenner, IBFD Thinker, Teacher, Traveler: Reimagining International Tax, September 1, 2021
• "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.