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Jeffrey M. Trinklein

Jeffrey
Trinklein

Partner

CONTACT INFO

jtrinklein@gibsondunn.com

TEL:+44 (0)20 7071 4224

FAX:+44 (0)20 7070 9224

London

Telephone House, 2-4 Temple Avenue, London, EC4Y 0HB United Kingdom

New York

200 Park Avenue, New York, NY 10166-0193 USA

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PRACTICE

Tax Executive Compensation and Employee Benefits Global Tax Controversy and Litigation Investment Funds Power and Renewables Private Equity Real Estate Investment Trust (REIT)

BIOGRAPHY

Jeffrey M. Trinklein is a partner in the London and New York offices of Gibson, Dunn & Crutcher, and a member of the Tax Practice Group. Mr. Trinklein has extensive experience in U.S. and international taxation, with special emphasis on advice to foreign clients with investments in the United States and advice to U.S. clients with foreign operations.

Mr. Trinklein’s areas of practice include advice to U.S. individuals and companies establishing investments outside the U.S., planning advice on worldwide investment structures and acquisition financing and general U.S. corporate and partnership tax planning. He has represented clients with tax structuring for a range of mergers and acquisition transactions, ranging from public company acquisitions, to private equity fund transactions, to the acquisition of a U.S. professional sports franchise. He has also assisted foreign countries with the drafting of proposed legislation.

Mr. Trinklein is ranked by The Best Lawyers in America®, Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business and The Legal 500 United States as a leading tax lawyer. Chambers USA describes Mr. Trinklein as “a creative and confidence-inspiring practitioner who can effectively communicate tax nuances” and “communicates clearly and is always very responsive and ready to assist, often in a compressed timeframe.” He is also recognised in Legal 500 UK 2023 for Corporate Tax, which previously noted that he “has a specialism in advising foreign clients with investments in the US, as well as US clients with foreign operations.”

Mr. Trinklein joined Gibson Dunn in 1985 and has previously worked in Gibson Dunn’s Munich, London, Dallas and Orange County offices. From 1998 to 2002, Mr. Trinklein was a member of the Adjunct Faculty at Southern Methodist University’s Dedman School of Law, where he taught courses on U.S. taxation of international transactions and financial derivatives. Mr. Trinklein has also served as an adjunct faculty member at the London Program of the University of Detroit School of Law and lectures and writes frequently on tax law topics. He has a working knowledge of German and French.

Publications

  • Author, “Sovereign Wealth Funds: Tax Makes a Difference,” ABANA Review (2008).

EDUCATION

University of Virginia - 1985 Juris Doctor

University of Chicago - 1982 Bachelor of Arts

ADMISSIONS

England & Wales - Solicitor - Registered Foreign Lawyer

New York Bar

RECENT PUBLICATIONS

Client Alert - January 4, 2023 | IRS and Treasury Issue Proposed Regulations Narrowing Domestically Controlled REIT Qualification Test and Revising Section 892 Exemption, as Well as Final Regulations Relating to Qualified Foreign Pension Funds
Client Alert - December 16, 2022 | IRS and Treasury Issue Proposed Regulations on Consolidated Group Ownership of CFC Stock for Certain Purposes
Client Alert - December 1, 2022 | Proposed U.S. Foreign Tax Credit Rules Provide Relief for Certain Taxpayers and Ideas for Others
Firm News - October 28, 2022 | Who’s Who Legal Recognizes Four Gibson Dunn Partners in Corporate Tax 2022
Firm News - July 8, 2022 | Expert Guides Recognizes Four Gibson Dunn Partners in Tax
Client Alert - May 12, 2022 | Introduction of Corporate Tax in the UAE
Firm News - November 5, 2021 | Who’s Who Legal 2021 Guides Recognize Ten Gibson Dunn Partners
Client Alert - August 10, 2021 | Senate Finance Committee Chairman Ron Wyden (D-OR) Introduces the “Ending The Carried Interest Loophole Act” That Would Require Current Ordinary Income Inclusions
Client Alert - May 29, 2021 | Biden Administration Releases Fiscal Year 2022 Budget, Together With a “Greenbook” Providing Detailed Descriptions of Proposed Changes to Federal Tax Law and Accompanying Revenue Estimates
Firm News - July 17, 2020 | Jeff Trinklein and Sandy Bhogal Recognized in Tax Expert Guide 2020
Client Alert - May 1, 2020 | IRS Issues Notice Clarifying Expenses Funded with Proceeds of Small Business Administration Loans under Paycheck Protection Program
Client Alert - March 25, 2020 | Tax-Favored Financial and Other Assistance to Employees in the Face of COVID-19
Firm News - January 30, 2020 | Who’s Who Legal Recognizes 15 Gibson Dunn Partners in Litigation, Corporate Tax and Private Funds
Client Alert - January 17, 2020 | What Impact Will Brexit Have on Derivative Benefits Test Under U.S. Double Tax Treaties?
Client Alert - October 15, 2019 | Treasury Releases Guidance on the Transition from LIBOR to Other Reference Rates
Client Alert - July 12, 2018 | The Politics of Brexit for those Outside the UK
Client Alert - January 16, 2018 | The Overhaul of France’s Tax Laws Has Been Enacted -What Will the 2018 Finance Act Change?
Client Alert - December 7, 2017 | Black and Grey: The EU Publishes Its Lists of Tax Havens
Client Alert - November 24, 2017 | International Investors to Be Liable to UK Tax on Capital Gains Derived from UK Real Estate from 2019
Client Alert - November 3, 2017 | House GOP Releases Major Tax Reform Bill
Client Alert - November 11, 2016 | IRS Issues Final and Proposed Regulations Addressing Partnerships and Section 956 and the Active Rents and Royalties Exception
Client Alert - September 30, 2016 | Sovereign Immunity Limits Imposed by the Justice Against Sponsors of Terrorism Act
Article - September 13, 2016 | The Gift of Worldwide Taxation
Client Alert - September 9, 2016 | IRS Releases Final Regulations Clarifying the Definition of Real Property for REITs
Client Alert - August 8, 2016 | IRS Issues Temporary Regulations for Early Election into New Partnership Audit Rules
Client Alert - July 25, 2016 | Is It Still Possible to Implement Tax-Free Step-Up of Real Estate Assets Held Through a French SCI?
Client Alert - June 14, 2016 | IRS Releases Temporary and Proposed Regulations Extending REIT Built-in Gain Recognition Period for Property Acquired from a C Corporation and Tightening the Rules for REIT Spinoffs
Client Alert - March 31, 2016 | District Court Issues Troubling Decision in Sun Capital Case: Private Equity Funds Formed “Partnership-in-Fact” and Were Engaged in “Trade or Business,” Liable for Withdrawal Liability Obligations of Portfolio Company
Client Alert - February 9, 2016 | Treasury Issues Temporary Regulations Regarding the Allocation of Partnership Foreign Tax Expenditures
Client Alert - December 29, 2015 | President Obama Signs Appropriations Bill Exempting Non-U.S. Pension Funds from FIRPTA, Taxing REIT Spinoffs, and Making Other Important Changes to the Taxation of U.S. Real Property Investments by Non-U.S. Investors and the REIT Rules
Client Alert - November 23, 2015 | Amendment to France-Luxembourg Tax Treaty Will Not Tax the Sale of Companies Owning French Real Estate Before 2017
Client Alert - November 12, 2015 | President Obama Signs Bipartisan Budget Act of 2015, Sweeping Aside Rules That Have Governed Tax Audits of Partnerships Since 1982
Client Alert - March 6, 2015 | ECJ Decision Halts 15.5% French Social Taxes on Income from French Property of Certain EU Residents, Inviting up to Two Years of Refunds
Client Alert - September 8, 2014 | Renegotiation of the France and Luxembourg Tax Treaty: Taxation of Real Estate Capital Gains Now Expanded by Way of a September 5, 2014 Amendment to the Treaty
Client Alert - September 8, 2014 | Renégociation De La Convention Fiscale France Luxembourg : Par Un 4ème Avenant, La France Se Voit Attribuer Le Droit D’imposer Les Plus-Values De Cession De Titres De Sociétés A Prépondérance Immobilière Détenant Des Immeubles En France
Webcasts - April 2, 2014 | Webcast – Using Chapter 11 to Forge Consensual Resolutions in Cross-Border Restructurings
Client Alert - May 22, 2013 | Obama Administration’s Fiscal Year 2014 Revenue Proposal Would Facilitate Investment in U.S. Real Property by Foreign Pension Funds
Client Alert - May 13, 2013 | Global Legal Insights – Corporate Tax: USA
Client Alert - January 22, 2013 | IRS Issues Detailed Final Regulations Under the FATCA Provisions of the HIRE Act
Client Alert - March 30, 2012 | UK Government Targets Foreign Owners of UK Residential Property
Client Alert - February 9, 2012 | IRS Proposes Detailed Regulations Under the FATCA Provisions of the HIRE Act
Client Alert - February 7, 2012 | Renegotiation of The France-Luxembourg Tax Treaty Targets Capital Gains on French Real Estate Companies
Client Alert - November 4, 2011 | IRS Proposes Regulations to Ease Tax Burdens on Government Investment Funds
Client Alert - August 9, 2011 | IRS Notices Extend Date for Implementation of FATCA Provisions of the HIRE Act and Provide Additional Guidance
Client Alert - December 20, 2010 | New Law Extends U.S. Income Tax Rates Through 2012
Client Alert - October 7, 2010 | IRS Issues Guidance on New FATCA Withholding Obligations
Client Alert - March 2, 2010 | FinCEN Proposes Rule to Clarify Which Persons Will Be Required to File FBARs and Which Accounts Will Be Reportable
Client Alert - November 10, 2009 | President Obama Signs Legislation Expanding Net Operating Loss Carryback
Client Alert - May 29, 2009 | Recent GAO Report on Sovereign Wealth Funds
Client Alert - April 7, 2009 | Legislation Reintroduced to Tax Carried Interests as Ordinary Income
Client Alert - February 17, 2009 | Stimulus Bill Tax Provisions
Client Alert - February 16, 2009 | Tanking bond prices spell opportunity for issuers
Article - February 1, 2006 | Delaware im Wettstreit mit Luxemburg
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