William McRae’s practice focuses on taxation and related matters, including complex cross-border corporate and financial transactions.

He regularly advises non-U.S. sovereign investors on structuring investments into the United States, and both U.S. and non-U.S. clients on the tax aspects of corporate acquisitions; forming and investing in private equity funds, real estate funds, and other investment vehicles; restructurings, including preservation and utilization of NOLs and other tax attributes, and management of COD income; and the taxation of equity derivatives and other financial products. He also has considerable experience advising multinational corporate groups on a variety of international planning issues, including FTC planning and repatriation strategies.

Bill is a member of New York State Bar Association, where he serves on the Tax Section Executive Committee. In that capacity, he was the primary author of a report from the Bar Association to the Treasury Department and the Internal Revenue Service regarding the taxation of sovereign wealth funds by the U.S., the primary recommendations of which have been implemented through proposed regulations on which taxpayers may currently rely.

Bill joined the firm in 1996 and became a partner in 2005.

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Notable Experience

Sovereign Wealth Funds

  • A leading UAE sovereign wealth fund in its investments in various U.S. and EU real estate-related funds, including Brookfield Strategic Real Estate Partners, Blackstone Real Estate Partners Europe, and Square Mile Partners.

  • Several leading UAE and GCC sovereign wealth funds as limited partners in their real estate, infrastructure, and credit fund investments and co-investments.

  • A leading GCC sovereign wealth fund in relation to LP investments into various funds, including in Makena; CITIC Capital China Partners III, an Asian fund; and AlpInvest, a secondaries fund.

  • A leading UAE sovereign wealth fund in relation to the restructuring and investment into a club-fund investing in infrastructure (renewable energies) in the U.S. and Canada.

  • A leading Asian sovereign wealth fund in its investments in a number of credit and private equity funds.

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Mergers, Acquisitions, and Joint Ventures

  • ESL Investments in its $5.2 billion acquisition of substantially all of Sears’ assets.

  • FEMSA in its acquisition of North American Corp. and WAXIE Sanitary Supply.

  • A syndicate of banks in Brookfield Asset Management’s $11.4 billion acquisition of Forest City Realty Trust.

  • American Express in the formation of a joint venture of its Global Business Travel division with an investor group led by Certares.

  • TPG in a $1.7 billion acquisition and recapitalization, together with Leonard Green & Partners, of Savers.

  • Warburg Pincus and Triton Containers International in Triton’s merger with TAL International, which created the world’s largest intermodal container lessor, with revenue generating assets valued at $8.7 billion.

  • Overseas Shipholding Group in its successful emergence from Chapter 11 and in its spin-off of International Seaways.

  • Brightstar and its founder in the $1.26 billion sale of a 57 percent interest to SoftBank.

  • TRAC Intermodal, a Fortress Investment Group portfolio company, in the sale of its domestic chassis fleet to Direct ChassisLink.

  • América Móvil in a range of matters, including in its $905 million acquisition of Nextel Brazil and $648 million acquisition of Telefónica’s operations in El Salvador and Guatemala.

  • American Tower in its $10.1 billion acquisition of CoreSite Realty Corporation.

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Private Equity Funds, Real Estate Funds, and Other Investment Vehicles

  • Hillhouse in the formation of Hillhouse Fund IV, the largest Asia-focused private equity fund ever raised with $10.5 billion in total commitments.

  • J.P. Morgan in the formation of numerous onshore and offshore conduit funds to permit high-net-worth individuals to invest in investment funds.

  • Angelo, Gordon & Co. in various fund matters.

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Selected Activities

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  • Member, Tax Section Executive Committee, New York State Bar Association
  • Faculty; Financial Institutions, Markets, and Transactions Training Series; 2023

Publications

Events