David F. Abbott

David Abbott is a highly respected transactional lawyer and tax litigator. He advises clients across a broad range of critical issues, with a particular focus on four key areas of corporate concern involving litigation and transactional issues.

David’s dispute resolution practice emphasizes tax litigation and controversy, as well as bankruptcy disputes.  He has experience with tax audits and appeals, and represents clients before the Tax Court and the US Court of Federal Claims. David’s current and past cases involve corporate acquisition-related issues, including valuation of fixed and intangible assets and inventory, payment of acquisition-related fees and financing-related issues such as debt versus equity characterizations, debt/equity swaps, transfer pricing and tax treatment of leasing transactions, including LILOs and so-called “SILOs” (sale-in/lease-out arrangements).  In addition, David has represented equity investors in Chapter 11 bankruptcy cases involving several leading airlines with respect to aircraft lease Tax Indemnity Agreement claims.

On the transactional side, David represents equity investors, lenders and lessees in equipment and real estate leasing transactions such as sale-leasebacks, leveraged and single-investor leasing, cross-border lease arrangements, QTE and lease-to-service contracts, acquisition and divestiture of leasing portfolios and leasing subsidiaries and related tax-oriented financing structures and debt instruments.  His transactional tax counsel also encompasses acquisitions and divestitures, financial products, consolidated return regulations, general corporate taxation and partnership taxation.