Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery LLP and is based in the Chicago office. He is head of the U.S. & International Tax Practice Group.
Lowell's practice focuses on international tax planning for multinational companies. He handles cross-border acquisitions, dispositions, mergers, reorganizations, joint ventures and financings. He advises concerning multi-jurisdictional business structures and the use of special purpose foreign entities. He also works with an extensive network of foreign lawyers on developing structures that minimize foreign taxes of U.S. multinationals without adversely affecting their U.S. tax position. Lowell was listed in the latest, as well as previous editions of Chambers Global: The World's Leading Lawyers for Business, Chambers USA: America's Leading Lawyers for Business, International Tax Review's World Tax Directory, The Best Lawyers in America, PLC Which Lawyer?, The International Who's Who Of Corporate Tax Lawyers, The Legal 500 United States, The International Who's Who of Business Lawyers, Who's Who Legal: Illinois and Euromoney's Guide to the World's Leading Tax Advisors and Best of the Best USA. Lowell has also been named an Illinois Super Lawyer by Law & Politics.
Lowell is a frequent lecturer. He has spoken on a variety of international topics for the Tax Executives Institute, American Bar Association, The University of Chicago Law School's Annual Federal Tax Conference, International Bar Association, GWU Annual Institute on International Taxation, Chicago Tax Club, Practising Law Institute, Bloomberg Tax Management Advisory Board and the International Fiscal Association. Lowell was an Adjunct Professor at the Northwestern University School of Law, where he taught Advanced International Taxation and is a frequent contributor to a blog dedicated to corporate taxation on Forbes.com. He is the editor-in-chief of CCH's International Tax Journal and has authored four portfolios on the tax treatment of U.S. controlled foreign corporations: 926 TM, Subpart F-General; 6220 TM, CFCs-Foreign Personal Holding Company Income; 928 TM, CFCs-Subpart F-Foreign Base Company Income and 930 TM, Subpart F-Sections 959-964, 1248 and Related Provisions. Lowell has published numerous articles on international topics.
Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute's International Tax Issues conferences and an International Tax Roundtable group that includes tax lawyers from the major European countries that meets twice a year to discuss significant cross-border topics. He is a fellow of the American College of Tax Counsel, and chairs the ABA Subcommittee for Controlled Foreign Corporations, PFICs and contract manufacturing. Lowell is also a member of the Planning Committee for the University of Chicago Law School's Annual Federal Tax Conference, USA Branch Counsel of the International Fiscal Association, chair of the ABA Committee on Foreign Activities of U.S. Taxpayers and a member of the Advisory Board of the GWU/IRS Annual Institute on International Taxation. In addition, Lowell is a member of the Bloomberg Tax Management International Journal's Advisory Board, the Bloomberg Tax Management Foreign Income Advisory Board, and the Board of Advisors of the International Tax Journal.
J.D., University of Illinois College of Law (1982) magna cum laude
B.S., University of Illinois at Chicago (1979) highest distinction
Bloomberg Tax Management Portfolios
CFCs—General Overview (Portfolio 926)
This Portfolio describes the rules for the U.S. federal income taxation of shareholders of controlled foreign corporations (CFCs) under Subpart F of the Internal Revenue Code.
CFCs — Sections 959-965 and 1248 (Portfolio 930)
This Portfolio describes the rules that apply to the repatriation of the earnings and profits of a CFC under Subpart F of the Internal Revenue Code.
CFCs — Foreign Personal Holding Company Income (Portfolio 6220)
This Portfolio provides a analysis of foreign personal holding company income, foreign base company income and "Subpart F income".
CFCs — Foreign Base Company Income (Other than FPHCI) (Portfolio 6240)
This Portfolio focuses on the provisions of §954 other than those pertaining to foreign personal holding company income.