Overview

Patrick Gallagher handles structuring and tax aspects of complex domestic and cross-border transactions for private equity and other clients, including acquisitions and divestitures, fund formation, public offerings and other financings, and restructurings.

Patrick has been named as a leading tax attorney in both Chambers USA, America's Leading Lawyers for Business (annually since 2005), which describes him as "someone who solves problems," has a "wonderful presence," and "[pays] scrupulous attention to all the details," and Who's Who Legal: Corporate Tax (annually since 2003). He has also been recognized in New York Super Lawyers every year since 2006 and The Legal 500 U.S.

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Thought Leadership

Publications

Ownership Attribution Rules, "Relatedness" and Large Partnerships, The Tax Club (2011)

Investments by Tax-Exempt Organizations:  Intersections and Collisions with the Taxable World, Taxes (2006)

Mergers, Acquisitions and Buyouts, Aspen Publishers (4 volume treatise updated semi-annually, 1989–present) (one of three principal co-authors with M. Ginsburg and  J. Levin)

Private Equity Funds — Selected U.S. Tax Issues, The Tax Club (2002)

NYSBA Tax Section, Report on the Taxation of Partnership Options and Convertible Securities, 94 Tax Notes 1179 (2002) (principal drafter)

Subsidiary Ownership After "Check-the-Box": Choosing Among Corporate, Single-Member LLC, and Partnership Forms, Taxes (1999)

Observations on the Taxation of Debt and Equity under the 1997 Act, The Tax Club (1997)

NYSBA Tax Section, Report on Proposed Treasury Regulations Section 1.1504-4:  Definition of "Affiliated Group," 56 Tax Notes 391 (1992) (principal author)

Principal author or co-author of numerous other reports for the New York State Bar Association Tax Section on topics including tax-free reorganizations and spin-offs, leveraged partnerships, and consolidated returns.

Memberships & Affiliations

New York State Bar Association, Tax Section:

  • Chair (2007)
  • Executive Committee (1993–present)
  • Co-Chair from time to time of Committees on Partnerships, Corporations, Reorganizations, Consolidated Returns

Private Investment Funds Tax Forum (Chair, 2011–2012)

American Bar Association Tax Section

Credentials

Admissions & Qualifications

  • 1989New York

Education

  • Harvard Law SchoolJ.D.cum laude1985
  • University of ChicagoM.A.1977
  • Pomona CollegeB.A.1974