Christopher T. Bird

Senior Counsel

Christopher T. Bird

Senior Counsel

Christopher Bird focuses his practice on advising U.S. and non-U.S. fund sponsors regarding the tax aspects of forming and operating private investment funds, including credit, buyout, venture capital, secondary, and funds of funds, as well as on advising fund sponsors regarding their internal economic arrangements. Chris has extensive experience advising various types of institutional investors in their investments in private investment funds and representing buyers and sellers in secondary transactions. He is a member of the firm’s Tax, Benefits, and Estate Planning Practice Group.

Chris regularly advises companies on U.S. tax issues relevant to equity compensation arrangements, including stock options, profits interests, and phantom equity, and on the golden parachute payment rules under Section 280G of the U.S. Internal Revenue Code.

Awards and Recognition

  • Recipient, Edith C. Blum Foundation Prize (for exceptional achievement in taxation)

Presentations and Publications

  • Co-Author, “Exit Planning: Family Offices Need Solid Foundations,” The Legal Special 2019, Private Equity International (PEI) (May 2019)
  • Co-Author, “Cyprus—Back to the Future: Cyprus, an Ancient Trading Center, has become a Glitzy New Presence on the International Tax Stage,” Practical U.S./International Tax Strategies (November 15, 2009)
  • Co-Author, “IRS Draws Lines for College Student Housing Organizations,” Taxation of Exempts, (September/October 2009)
  • Co-Author, “Should the Commensurate Test Force Greater Spending By Public Charities?,” The Exempt Organization Tax Review (April 2009)
22 November 2023 Article

YA Global Investments, LP v. Commissioner: Tax Court Rules that Fund was Engaged in U.S. Trade or Business

In a widely anticipated opinion, on November 15, 2023 the U.S. Tax Court ruled that a fund was engaged in a U.S. trade or business through the activities of its investment manager, and that the fund was also a “dealer in securities” subject to the mark-to-market accounting rules of Section 475.
07 September 2023 Article

Another Fund Manager Sues IRS Over Application of “Limited Partner” Exception to Self-Employment Taxes

On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management (“Point72”) filed a petition with the Tax Court contesting the IRS’s position that its owner, billionaire and New York Mets team owner Steve Cohen, cannot claim the “limited partner” exception to exclude US$344 million in partnership income from self-employment tax.
27 April 2023 Deals and Wins

Foley Represents Torc Robotics in Acquisition of Algolux

Foley & Lardner LLP served as legal adviser to Torc Robotics, a pioneer in commercializing self-driving vehicle technology, in closing a strategic transaction to acquire Algolux Inc., an internationally recognized leader in autonomous vehicle perception technology.
11 August 2022 Newsletters

Tax Provisions in the Inflation Reduction Act of 2022

On August 7, 2022, the Senate passed a major climate, health and tax bill through the budget reconciliation process.