Joshua R. Williams advises on a broad range of U.S. and international tax matters, with a focus on the formation and operation of domestic and offshore private investment funds and on the tax aspects of domestic and international real estate transactions, as well as project finance and renewable energy transactions.
Practice & Background
Mr. Williams regularly advises on international tax issues that arise with respect to investments in the United States by non-U.S. investors (including investors subject to special U.S. tax treatment), as well as investments outside of the United States by U.S. persons. Mr. Williams has substantial transactional experience in the real estate area and regularly advises real estate funds and other market participants on a broad array of U.S. and international tax issues presented by investments in real estate, including issues raised under the real estate investment trust rules. He also advises creditors of bankrupt and financially troubled companies on a variety of issues, including restructuring of debt, preservation of tax attributes and issues arising under the consolidated return regime. Additionally, he has experience in structuring tax-driven vehicles, such as sale-leasebacks, flip partnerships, inverted leases and other structures, for the acquisition and financing of renewable energy assets.
Prior to joining Akin Gump, Mr. Williams was an associate at two other major U.S. law firms, where he focused on U.S. and international tax matters.
Mr. Williams received his B.S. summa cum laude in accounting in 1999 from the University of South Carolina and his J.D. cum laude in 2002 from the University of South Carolina School of Law, where he was a member of the Order of the Coif and served as the student works editor of the South Carolina Law Review. Mr. Williams also received an LL.M. in taxation in 2003 from the New York University School of Law.
Sample engagements have included the representation of:
- NRG Energy, Inc. with respect to Treasury Grant and tax matters in the financing of California Valley Solar Ranch, a $1.5 billion solar photovoltaic project supported by a Department of Energy loan guarantee
- an investment fund in its acquisition of significant debt and equity positions in RCS Capital Corporation and American Realty Capital Properties, Inc.
- an investment fund in its purchase of leasehold interests in wireless cell tower easements, which raised a number of complex REIT and real estate-related tax issues
- a number of investment funds in connection with investments in distressed debt securities in the United States and abroad
- a publicly traded company in connection with a successful private letter ruling request that involved novel consolidated return issues
- a hedge fund in connection with an investment in multiple hotel properties throughout the United States
- a private equity fund in connection with its structuring and disposition of intellectual property investments held through a multinational structure that involved various European jurisdictions
- various investment funds in connection with divestitures and restructurings of general partner and manager vehicles
- investment funds formed for the purpose of investing in contingent future royalties and other cash flows generated from pharmaceutical and other intellectual property rights
- investment funds in connection with acquisitions and dispositions of skilled nursing and senior living facilities.