Mr. Rachuba’s recent client successes include advising:

• A New York-based private equity fund on its acquisition of an Australian mortgage business.
• A San Francisco-based private equity fund on the recapitalization and IPO of its portfolio company.
• A Los-Angeles based private equity fund on multiple international acquisitions.
• Los Angeles and New York-based publicly-traded partnerships on converting to corporations post-2017 tax reform.
• Various private equity and hedge fund professionals on solutions to the new “3 year carry” capital gain rules.
• A Los Angeles-based credit fund manager on the tax implications of setting up a Japanese KK subadvisor.
• Various industry professionals on self-employment tax strategies.
• An energy fund on Latin American power purchase agreement investments.
• A Singapore sovereign wealth fund on investments in loan origination and life settlement platforms.
• A sovereign wealth fund on the implications of 2017 tax reform for its MNC investee companies, such as airlines and telecoms.
• A U.S. credit fund on airplane leasing transactions in Ireland.
• Clients on the U.S. tax aspects of structuring an India-focused VC/PE fund.
• A U.S. hedge fund on a restructuring of an Atlanta-based real estate investment.
• A U.S. credit fund on setting up an Irish treaty platform for its direct lending investments.
• A Canadian sovereign wealth fund on an acquisition of multiple U.S. partnerships and corporations from a San Francisco private equity fund.
• A Hong Kong-based asset manager on U.S. tax deferral techniques/platforms.
• A credit fund on the acquisition of multiple blocker entities from a U.S. private equity fund.
• Clients on the availability of foreign tax credits for a withholding tax imposed on a series of VC funds selling an India investment to a multinational retailer.
• A hedge fund on the acquisition of Latin American receivables.
• A Middle Eastern sovereign fund on investment in a Brazil clean energy platform.

• Speaker on UBTI issues, Stanford Management Company annual legal counsel conference, Palo Alto
• Speaker, Wells Fargo Tax Reform panel for hedge funds, San Francisco
• Speaker, BofA Merrill Lynch hedge fund tax roundtable, San Francisco
• Speaker, PEI Private Equity Conference, San Francisco
• Speaker, American Bar Association Tax Committee meeting, San Francisco
• Speaker, EY Alternative Funds Symposia, San Francisco and Los Angeles
• Speaker, EY International Tax Conferences, New York and Singapore