Kyle Pine Featured in Q&A on Tax Practice and Private Capital Trends
Foley & Lardner LLP partner Kyle Pine is featured in a recent Bloomberg Tax “Five Questions” profile, offering perspective on the current landscape of tax practice, the impact of private capital transactions, and key issues facing practitioners.
Pine observed that today’s tax practitioners face “growing complexity in deal dynamics, including more investment activity from private equity sponsors, family offices, and other private capital providers; changing rules and regulations coupled with heightened compliance and dispute risks; and fast-paced shifts in technology.”
On deal risk and transaction timelines, he noted “that pressure can be felt especially in private capital transactions, where sponsors often operate on compressed timelines and expect practical solutions that keep deals moving.” Pine emphasized the importance of a “creative solution that balances the exposure against the parties’ commercial objectives while preserving transaction momentum and deal certainty.”
He also highlighted the value of mentorship, reflecting that “the life of a young tax practitioner is one of ‘firsts,’” from learning new areas of tax law to understanding transaction structures and the objectives that drive private capital investments.
Asked what section of the tax code he would most like to change, Pine pointed to Section 951A, calling it “ripe for change due to its relentless complexity and compliance burdens.” He said the regime creates uncertainty for private capital investors and multinational businesses evaluating cross-border investments and acquisitions.
He underscored that “economic reality drives tax outcomes,” noting that tax consequences ultimately depend on a transaction’s underlying economic substance and practical effects.
