Billy Abbott


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Billy Abbott advises clients on tax matters in the context of private and public mergers and acquisitions, the formation of, and investments in, private equity funds, partnerships and limited liability companies (LLCs), debt and equity securities issuances, and large-scale syndicated credit facilities.

Billy understands that every business’s tax position is different and works to ensure that his clients achieve the best result possible in any transaction. He represents a wide range of enterprises, including start-ups, large multinational corporations, financial institutions, private equity, real estate, and other investment funds, and traditional and alternative energy companies.


Honors & Awards

  • Recommended by The Legal 500 US in Tax


Bar Admissions

  • California
  • New York


  • Stanford University, J.D.
  • College of William and Mary, B.A., Government and Mathematics

Professional Activities


  • Honorable Mary Ann Cohen, US Tax Court
  • Represented major technology companies in the acquisition of domestic and foreign target companies 
  • Represented issuers and underwriters in multibillion-dollar issuances of publicly traded securities 
  • Represented significant investors in private equity funds including US taxable investors, US tax-exempt entities and foreign investors (including foreign governments) 
  • Advised on US tax matters with respect to the formation of both domestic US and non-US private equity funds 
  • Advised on Qualified Opportunity Zone matters, including structuring those Qualified Opportunity Funds and investment in them 
  • Represented a leading US company in tax-related litigation before the European Commission

Press Releases

Alerts and Publications

Final Regulations Alleviate Many Concerns About US Tax Treatment of Carried Interest, but Some Questions Remain

January 16, 2021

New Regulations May Help Foreign Corporations Undertaking an IPO Avoid PFIC Status

January 8, 2021

New Regulations Clarify the Application of U.S. Withholding Regime to Secondary Transfers of Partnership Interests by Non-U.S. Partners

October 20, 2020

Proposed Regulations Provide Guidance for TCJA’s New Carried Interest Rules

August 7, 2020

Companies Should Consider Adopting Net Operating Loss Rights Plans in the Wake of the Coronavirus (COVID-19) to Protect Net Operating Losses

March 20, 2020

Final Regulations Expand Prospects for Businesses and Investors in Qualified Opportunity Zones

March 12, 2020

Supreme Court Strikes Down “Bob Richards” Rule, Impacting Consolidated Group Members’ Entitlement to Tax Refunds in Bankruptcy Proceedings

March 2, 2020

Cryptocurrency Industry and Investors Receive New Guidance on Key Tax Issues: Hard Forks, Airdrops, and Other Virtual Currency Transactions Addressed by IRS

October 10, 2019