Nicholas C. Mowbray

Associate

Washington, D.C.
T +1.202.861.1704
F +1.202.861.1783

Overview

Nicholas Mowbray focuses his practice on U.S. and international tax matters. Nicholas regularly advises clients on ways to enhance the tax efficiency of commercial transactions and operating structures, while also counseling clients in restructurings, acquisitions, joint ventures and dispositions. His work across industries includes advising clients in the areas of asset management, banking, insurance, life sciences and consumer products. Prior to joining the firm, Nicholas spent more than six years in public accounting, working in both Chicago and London.

*Not admitted in the District of Columbia, admitted in Illinois. Practicing pursuant to D.C. Rule 49(c)(8) under the direct supervision of Roger Brown during pendency of application for admission to the District of Columbia.

Select Experience

Asset Management
  • Created and implemented protocols for traders of a non-U.S. hedge fund with respect to publicly traded partnerships and derivatives written over U.S. equities.
Financing
  • Created tax-efficient investment strategy for a non-U.S. investor investing in a U.S. broker-dealer.
Restructuring
  • Created restructuring and entity simplification plan for a U.S. multinational with respect to its non-U.S. holdings in China, Mexico and the Netherlands.
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Experience

Asset Management
  • Created and implemented protocols for traders of a non-U.S. hedge fund with respect to publicly traded partnerships and derivatives written over U.S. equities.
  • Designed and implemented structures for a non-U.S. alternative lending fund with respect to lending and aircraft leasing in the United States.
Financing
  • Created tax-efficient investment strategy for a non-U.S. investor investing in a U.S. broker-dealer.
Restructuring
  • Created restructuring and entity simplification plan for a U.S. multinational with respect to its non-U.S. holdings in China, Mexico and the Netherlands.
  • Advised U.S. multinational on how to integrate a non-U.S. acquired business into its operating model and how to restructure its acquisition indebtedness.
International Tax Planning
  • Advised U.S. multinational on restructuring considerations with respect to GILTI.
  • Advised U.S. multinational on functions and services qualifying for FDII.
  • Designed and implemented the transfer of IP by a U.S. multinational to a foreign subsidiary.

Recognitions and Memberships

Memberships

  • American Bar Association: Tax Section

Publications

Alerts

Admissions

  • U.S. Tax Court
  • U.S. District Court, Northern District of Illinois
  • Illinois
  • [*Not admitted in the District of Columbia, admitted in Illinois. Practicing pursuant to D.C. Rule 49(c)(8) under the direct supervision of Roger Brown during pendency of application for admission to the District of Columbia.]

Education

  • LL.M., Taxation, Northwestern University School of Law, 2014, with honors
  • J.D., Chicago-Kent College of Law, Illinois Institute of Technology, 2010; Student Bar Association, Vice President
  • B.A., University of Michigan, 2006

Languages

  • Spanish

Blog

In The Blogs

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Blockchain Monitor
Blockchain for NASA and IoT, Developments in Crypto Products and Payments, Cryptocurrency Exchange Hacked
By Roger M. Brown, Nicholas C. Mowbray, Robert A. Musiala Jr., Simone O. Otenaike, Diana J. Stern, Joanna F. Wasick
January 18, 2019
In this issue: • The Blockchain Effect: NASA, IoT, Supply Chain and State Initiatives • Blockchain Announcements From Traditional Financial Institutions and Emerging Platforms • Cryptocurrency Exchanges and Payment Providers Announce New...
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Blockchain Monitor
New Blockchain Products, an FBI Raid, the $11 Billion Bitcoin Case, Hackers Strike With a 51 Percent Attack and Crypto Tax Analysis
By Roger M. Brown, Heather K. P. Fincher, Nicholas C. Mowbray, Robert A. Musiala Jr., Simone O. Otenaike, Joanna F. Wasick
January 11, 2019
In this issue: • New Cryptocurrency Financial Products and Platforms Announced • An FBI Raid, the $11 Billion Bitcoin Case, and Other Enforcement and Regulatory Actions in the U.S. and Abroad • Hackers Strike With 51 Percent Attack and...
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Blockchain Monitor
Studies Analyze Cryptocurrency Market, New Announcements in Payments, Enterprise and Threats
By Roger M. Brown, Heather K. P. Fincher, Shea M. Leitch, Nicholas C. Mowbray, Robert A. Musiala Jr., Simone O. Otenaike
December 21, 2018
In this issue: • Multiple Studies Analyze Recent Cryptocurrency Market Trends • Stablecoins, “Trading Pairs” and Other Developments in Cryptocurrency Payments • Threat Update: Ransomware, Crypto-mining Malware, BTMs and ICO Fraud Schemes •...
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