Michael R. Louis

Michael R. Louis is a tax attorney and focuses his practice on global tax planning, multi-jurisdictional mergers and acquisitions, restructurings, joint venture formations, and international tax controversies. Mr. Louis is also an Adjunct Professor of Tax Law at the SMU Dedman School of Law, where he has taught International Tax and the Taxation of Financial Products.

Biography

Mr. Louis joined FD Law in 2022 after serving as Senior Tax Counsel for Fluor Corporation, a publicly traded multinational company delivering engineering, procurement, and construction services to a global client base. In that role, Mr. Louis advised on the tax-efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations, and multi-jurisdictional master service agreements. Mr. Louis also supported the successful resolution of domestic and international tax audits, arbitration proceedings, and litigation. Prior to that, Mr. Louis was a Tax Partner at McDermott Will & Emery and advised clients on tax matters. Early in his career, Mr. Louis was a Law Clerk in Goldman Sachs’s tax department, where he analyzed the tax consequences financial and organizational decisions may have on the organization and its clients. He also helped review and update the tax department’s federal income tax withholding and reporting compliance guidelines. Mr.Louis was an undergraduate history major and served as a research assistant for Dr. Mike Wallace. He researched and organized primary and secondary source materials on New York City for Dr. Wallace’s work on Greater Gotham: The History of New York from 1898-1919.

Representative Recent Engagements

Advised a large privately held multinational enterprise on the U.S. federal income tax consequences of multiple refinancing and restructuring transactions that culminated with a public listing.
Advised on the restructuring and divestiture of an international equipment and fleet services business.
Performed tax due diligence of a U.S. headquartered service company with operations across Europe and the Middle East.
Advised on the restructuring and refinancing of an oil and gas operator in the Permian Basin and Colorado.
Provided transactional tax support for a multinational company providing technical services to a global client base.
Advised on the initial public offering and de-SPAC for a leading carbon-free energy company.
Advised a professional services company in connection with an offering of cumulative perpetual convertible preferred stock.
Advised on the structure and operations of a Joint Venture serving as the engineering, procurement, and construction contractor for an international LNG facility.
Advised on the structure and operations of a partnership selected to design, build, finance, operate and maintain a cross-border infrastructure project.
Developed a curriculum for training on the international provisions of the 2017 Tax Cuts and Jobs Act (e.g. GILTI, BEAT, and FIDII) and transfer pricing rules.
Provided tax advisory support to a private non-profit foundation.
Represented a multinational company in summons enforcement litigation regarding assertions of privilege for tax advice and related U.S. federal income tax audit of complex cross-border restructuring and refinancing transactions.
Represented taxpayers through competent authority proceedings in multiple jurisdictions.
Pro Bono representation of a taxpayer claiming innocent spouse relief under Section 6015 in a matter where the IRS conceded in full and granted the requested relief. The case was featured in the ABA Tax Times. See, Roberson, Andrew R., A Team Effort by Tax Helpers 40 ABA Tax Times 28 (2020-2021).