- Indiana, 2016
New York, 2023
Zachary provides practical and creative solutions to clients’ complex tax issues.
Zachary acts for clients on the tax aspects of public and private mergers and acquisitions, financings and other commercial transactions. He has assisted on a diverse range of tax matters, including tax planning, disputes with the Internal Revenue Service and state tax agencies, and compliance with reporting and withholding obligations.
Prior to joining Davies, Zachary worked for a large international law firm in New York.
Acted for Sprott Inc. in the formation of Sprott Private Resource Streaming and Royalty Annex Fund, a US$310-million annex fund that invests alongside Sprott’s first streaming fund, which brings the combined total assets under management of Sprott Resource Streaming and Royalty Corp. in both funds to US$1.1 billion.
Acted as tax counsel to Foodtastic Inc., a leading franchisor of restaurant brands in Canada, in its C$74.4-million acquisition of Freshii Inc.
Fulcrum Capital Partners
Acted for Fulcrum Capital Partners in the sale of Kore Outdoor Inc. to Ironbridge Equity Partners.
Birch Hill Equity Partners
Acted for Birch Hill Equity Partners in its joint acquisition (and related financing) with Investissement Québec of Québec-based Polycor Inc., the largest quarrier of natural stone in the world.
Acted for Hydrostor Inc., a developer of Advanced Compressed Air Energy Storage (A-CAES) projects, in securing a US$250-million preferred equity financing commitment from Goldman Sachs Asset Management - one of the largest investments in the emerging long-duration energy storage sector.
Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties
Mar. 22, 2023 - In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of Foreign Bank and Financial Accounts, more commonly referred to...
U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023
Feb. 21, 2023 - As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022 In 2022 we finally saw some movement on President Biden’s tax policy with the...
Upcoming Proposed Regulatory Changes to Stock Buyback Excise Tax
Dec. 29, 2022 - With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically, we address exceptions for (i) a broad new per se funding rule...
U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward
Aug. 18, 2022 - The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments, including the expansion, extension and creation of numerous tax...
U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022
Mar. 03, 2022 - Review of U.S. Tax Developments in 2021 Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th president of the United States. As we went to press last year, runoff...
Revised U.S. Tax Proposals Will Affect Foreign Investment
Nov. 08, 2021 - The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). The Framework reflects a significant reduction in the scope of the...
House Democrats Release Details on Proposed Tax Increases
Sept. 16, 2021 - Democrats on the House Ways and Means Committee have released a package of tax provisions (Ways and Means Proposal) that, if enacted, would provide funding for the infrastructure legislation that has been making headlines all summer (Infrastructure Legislation). The changes to the current tax laws...
Biden Proposes to Sharply Increase Taxes on Corporations and High-Income Individuals, While Encouraging Investment in Renewable Energy
June 03, 2021 - As expected, President Biden’s administration released a $6-trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean energy and certain infrastructure projects. The Treasury Department...
Biden Administration Unveils Tax Plan to Boost Investments in Infrastructure
Apr. 06, 2021 - President Biden and his administration recently released the American Jobs Plan, which provides additional detail on policies that were discussed throughout President Biden’s campaign and the early days of his administration. Through the American Jobs Plan, which was released on March 31, 2021,...