O’Melveny Worldwide

Billy Abbott advises clients on tax matters arising from private and public mergers and acquisitions, asset management funds, digital assets, complex cross-border structuring and more. 

He represents a wide range of enterprises, including start-ups, large multinational corporations, financial institutions, private equity, real estate, and other investment funds, sovereign wealth and foreign pension funds, financial technology creators and investors, among others. A talented and versatile corporate tax lawyer, Billy is a trusted advisor to his clients who appreciate his collaborative approach, his broad and deep technical expertise and his ability to distill complex tax matters into clear and helpful guidance.  Billy is also committed to pro bono efforts, primarily assisting non-profit organizations apply for tax exempt status and manage their corporate concerns in a range of fields, from education to criminal justice to supporting the LGBTQ+ community.

Get to Know Billy

What do you enjoy most about your job?

For our clients, tax issues are incredibly important, but can also be quite daunting. I spend much of my day immersed in the highly technical and complex world of tax law, but our clients are rightfully focused on growing their business or successfully completing a transaction. What I enjoy most is bridging that gap—explaining and breaking down the most difficult tax issues facing our clients into clear, digestible guidance. By promoting our clients’ understanding about tax issues, they feel confident in their decisions and that they have achieved the best possible outcome.

Why did you become a tax lawyer?

Tax combines what I view as my best skills—the ability to think logically but also critically about a complex set of rules. As an undergraduate studying math, I developed my ability to work through difficult problems of logic, which is critical to applying the tax law to real world situations. At the same time, studying government helped me to understand why the laws were passed, which is key to understanding how tax authorities will apply that law. Entering practice, what I liked most about my academic experience translated perfectly into helping clients solve their real world problems.

What is the most rewarding part of your work?

In addition to helping clients achieve great results, and the personal intellectual challenge of working in the tax law, I have the opportunity to work on incredibly rewarding pro bono matters. I have helped non-profit organizations working in areas I am passionate about to solve their tax and corporate issues. I have worked with organizations that help formerly incarcerated individuals reenter society, build spaces for the LGBTQ+ community and create economic opportunities for underprivileged individuals. Combining my commercial skills with improving people’s lives and supporting diversity and inclusion adds greater meaning to my work.

How do you keep clients up to speed with the constantly changing tax law?

Changes in the tax law can impact our clients immediately, so one of the most important responsibilities of a tax lawyer is educating our clients about those changes. Our clients know that I take that responsibility seriously through direct experience, but we also update them through client alerts on new issues relevant to them. I also have been asked to provide those updates to a wider audience on a number of occasions through offering external trainings, including presenting on rules for qualified foreign pension funds for Strafford and on carried interest changes for several tax conferences.

M&A Transactions

  • Represents numerous private equity clients in portfolio company investments, acquisitions and dispositions
  • Represents public and private companies in acquisitions of corporations, partnerships, LLCs and other businesses
  • Represented CJ ENM in its acquisition of Endeavor Content
  • Represented HID Global Corporation in numerous acquisitions including of Crossmatch and Mercury Security
  • Represented DigitalGlobe in its US$3.6 billion Sale to MDA

Asset Management

  • Advises sovereign wealth funds and foreign pension funds on US tax matters relating to their investments into private equity and other investment funds
  • Advises private equity and venture capital funds on fund structuring and other US tax matters for formation, secondary acquisitions and transfers and portfolio company management
  • Advises on Qualified Opportunity Zone structuring and investment matters

Financial Technology and Emerging Companies

  • Advises cutting-edge cryptocurrency and digital asset companies and investment funds on their US tax strategies
  • Advises early stage companies and their investors on critical tax structuring concerns, including complex preferred stock offerings and qualified small business stock issues

Other Tax Matters

  • Represented numerous companies and underwriters on listings with US and Hong Kong stock exchanges, including Tiger Brokers in their US$183 million offering on Nasdaq and the underwriters for the US$145 million listing by Shanghai HeartCare Medical Technology Corporation Limited on the HKSE
  • Represented a leading US company in tax-related litigation before the European Commission


Bar Admissions

  • California
  • New York


  • Stanford University, J.D.: Senior Production Editor, Executive Board, Stanford Law Review
  • College of William and Mary, B.A., Government and Mathematics: summa cum laude

Honors & Awards

  • Recommended by The Legal 500 US in Tax

Professional Activities

Speaking Engagements

  • HSU Untied Podcast: Interview with Billy Abbott (February 2024)
  • “IRS Final Regulations on FIRPTA Exemption for Qualified Foreign Pension Funds,” Strafford Webinars (March 2023)
  • “Blockchain and Beyond: The Interaction Between Distributed Ledger Technology and the Law”, Chapman Law School (January 2023)
  • “Decentralized Automated Organizations (DAOs): Practical Applications and Legal Framework,” Practising Law Institute (November 2022)
  • “Carried Interest After the TCJA: New Rules and Potential Solutions,” Oregon Tax Institute (September 2020)
  • “Carried Interests After TCJA,” USC Gould School of Law 2019 Tax Institute (January 2019)


  • “The Anything Asset: The Tax Classification of Cryptocurrency, NFTs, DAOs and Other Digital Assets,” Chapman Law Review, Volume 26 (forthcoming May 2023)
  • “How to Mitigate the Effects of DOMA on State Tax Filing,” State Tax Notes (August 1, 2010)


  • “Decentralized Autonomous Organizations (DAOs): Overview,” Thomson Reuters Practical Law (November 29, 2022)
  • “Calif. Tax on Asset Manager Fees Would Have Wide Reach,” Law360 (July 17, 2015)


  • The Honorable Mary Ann Cohen, US Tax Court