Four Decades for Justice
Andrew W. Needham retired from Cravath’s Tax Department in 2021. As a partner, his practice concentrated on tax advisory work in domestic and cross‑border mergers and acquisitions, spin‑offs, private equity fund formation and partnership taxation.
Mr. Needham’s clients included Barrick Gold, BDT Capital Partners, British American Tobacco, Brookfield Asset Management, Brunswick, Cincinnati Bell, Crown Castle, CyrusOne, Florida East Coast Railway, Fortress, FS Investments, Hasbro, IBM, Johnson & Johnson, MarkWest, Martin Marietta, New Media, Peabody Energy, Spectranetics, Unilever, US Foods, Weyerhaeuser and The Williams Companies, as well as numerous investment banking firms.
In 2012, Mr. Needham served as Chair of the New York State Bar Association Tax Section and is currently a member of its Executive Committee. He is also a member of the Bloomberg BNA Corporate Advisory Board, The Harvard Tax Club, the Private Investment Funds Tax Forum and the REIT Tax Club, as well as a frequent speaker at various tax conferences.
Mr. Needham is the author of many published articles, including “Bonus Depreciation: Basis Adjustments under Subchapter K,” 160 Tax Notes 41 (2018); “The Problem with Stuffing Allocations,” 141 Tax Notes 737 (2013); “Do the Market Discount Rules Apply to Distressed Debt?: Probably Not,” Journal of Tax’n of Financial Instruments (2009); “Private Equity Funds,” 735‑3rd T.M. Portfolio (2015); and “Hedge Funds,” 736‑2nd T.M. Portfolio (2015).
Mr. Needham was repeatedly recognized as a leading tax practitioner by, among others, Chambers USA, Chambers Global, The Legal 500 US, The Best Lawyers in America and Who’s Who Legal: Corporate Tax. He was also named to The Legal 500 US Hall of Fame in the International Tax category.
Mr. Needham received a B.A. from the University of Arizona in 1982, a J.D. and an LL.M. from Georgetown University Law Center, in 1986 and 1990, respectively, and an M.B.A. from the Wharton School of the University of Pennsylvania in 1992.
In 2012, Mr. Needham served as Chair of the New York State Bar Association Tax Section and is currently a member of its Executive Committee. He is also a member of the Bloomberg BNA Corporate Advisory Board, The Harvard Tax Club, the Private Investment Funds Tax Forum and the REIT Tax Club, as well as a frequent speaker at various tax conferences.
Mr. Needham is the author of many published articles, including “Bonus Depreciation: Basis Adjustments under Subchapter K,” 160 Tax Notes 41 (2018); “The Problem with Stuffing Allocations,” 141 Tax Notes 737 (2013); “Do the Market Discount Rules Apply to Distressed Debt?: Probably Not,” Journal of Tax’n of Financial Instruments (2009); “Private Equity Funds,” 735‑3rd T.M. Portfolio (2015); and “Hedge Funds,” 736‑2nd T.M. Portfolio (2015).
Mr. Needham was repeatedly recognized as a leading tax practitioner by, among others, Chambers USA, Chambers Global, The Legal 500 US, The Best Lawyers in America and Who’s Who Legal: Corporate Tax. He was also named to The Legal 500 US Hall of Fame in the International Tax category.
Mr. Needham received a B.A. from the University of Arizona in 1982, a J.D. and an LL.M. from Georgetown University Law Center, in 1986 and 1990, respectively, and an M.B.A. from the Wharton School of the University of Pennsylvania in 1992.
Activities & Publications
May 05, 2021
On May 4, 2021, Cravath prepared for its clients a memo entitled “The Federal Reserve, FDIC and OCC Release Proposal on Tax Allocation Agreements and Invite Comment,” which examined a newly proposed rule that would codify, and make additions to, existing guidance on income tax allocation agreements among banks and their holding companies and affiliates. The rule, proposed by the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, would require any bank that files federal or state income tax returns as part of a consolidated group that includes members other than the bank and its subsidiaries to enter into a tax allocation agreement containing specified terms. The memo provides insight on general requirements included in the rule, required provisions for tax allocation agreements and other considerations relevant to banks during tax filing.
Andrew W. Needham retired from Cravath’s Tax Department in 2021. As a partner, his practice concentrated on tax advisory work in domestic and cross‑border mergers and acquisitions, spin‑offs, private equity fund formation and partnership taxation.
Mr. Needham’s clients included Barrick Gold, BDT Capital Partners, British American Tobacco, Brookfield Asset Management, Brunswick, Cincinnati Bell, Crown Castle, CyrusOne, Florida East Coast Railway, Fortress, FS Investments, Hasbro, IBM, Johnson & Johnson, MarkWest, Martin Marietta, New Media, Peabody Energy, Spectranetics, Unilever, US Foods, Weyerhaeuser and The Williams Companies, as well as numerous investment banking firms.
In 2012, Mr. Needham served as Chair of the New York State Bar Association Tax Section and is currently a member of its Executive Committee. He is also a member of the Bloomberg BNA Corporate Advisory Board, The Harvard Tax Club, the Private Investment Funds Tax Forum and the REIT Tax Club, as well as a frequent speaker at various tax conferences.
Mr. Needham is the author of many published articles, including “Bonus Depreciation: Basis Adjustments under Subchapter K,” 160 Tax Notes 41 (2018); “The Problem with Stuffing Allocations,” 141 Tax Notes 737 (2013); “Do the Market Discount Rules Apply to Distressed Debt?: Probably Not,” Journal of Tax’n of Financial Instruments (2009); “Private Equity Funds,” 735‑3rd T.M. Portfolio (2015); and “Hedge Funds,” 736‑2nd T.M. Portfolio (2015).
Mr. Needham was repeatedly recognized as a leading tax practitioner by, among others, Chambers USA, Chambers Global, The Legal 500 US, The Best Lawyers in America and Who’s Who Legal: Corporate Tax. He was also named to The Legal 500 US Hall of Fame in the International Tax category.
Mr. Needham received a B.A. from the University of Arizona in 1982, a J.D. and an LL.M. from Georgetown University Law Center, in 1986 and 1990, respectively, and an M.B.A. from the Wharton School of the University of Pennsylvania in 1992.
In 2012, Mr. Needham served as Chair of the New York State Bar Association Tax Section and is currently a member of its Executive Committee. He is also a member of the Bloomberg BNA Corporate Advisory Board, The Harvard Tax Club, the Private Investment Funds Tax Forum and the REIT Tax Club, as well as a frequent speaker at various tax conferences.
Mr. Needham is the author of many published articles, including “Bonus Depreciation: Basis Adjustments under Subchapter K,” 160 Tax Notes 41 (2018); “The Problem with Stuffing Allocations,” 141 Tax Notes 737 (2013); “Do the Market Discount Rules Apply to Distressed Debt?: Probably Not,” Journal of Tax’n of Financial Instruments (2009); “Private Equity Funds,” 735‑3rd T.M. Portfolio (2015); and “Hedge Funds,” 736‑2nd T.M. Portfolio (2015).
Mr. Needham was repeatedly recognized as a leading tax practitioner by, among others, Chambers USA, Chambers Global, The Legal 500 US, The Best Lawyers in America and Who’s Who Legal: Corporate Tax. He was also named to The Legal 500 US Hall of Fame in the International Tax category.
Mr. Needham received a B.A. from the University of Arizona in 1982, a J.D. and an LL.M. from Georgetown University Law Center, in 1986 and 1990, respectively, and an M.B.A. from the Wharton School of the University of Pennsylvania in 1992.
Activities & Publications
May 05, 2021
On May 4, 2021, Cravath prepared for its clients a memo entitled “The Federal Reserve, FDIC and OCC Release Proposal on Tax Allocation Agreements and Invite Comment,” which examined a newly proposed rule that would codify, and make additions to, existing guidance on income tax allocation agreements among banks and their holding companies and affiliates. The rule, proposed by the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, would require any bank that files federal or state income tax returns as part of a consolidated group that includes members other than the bank and its subsidiaries to enter into a tax allocation agreement containing specified terms. The memo provides insight on general requirements included in the rule, required provisions for tax allocation agreements and other considerations relevant to banks during tax filing.
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