Leah Davis Patrick

Since joining Kirkland, Leah has been involved in the following matters:

• Partnership proceedings before IRS Exam involving valuation issues for solar and wind projects
• Partnership proceeding before IRS Exam and IRS Appeals involving loss limitation and expense issues
• Partnership proceeding in Tax Court involving procedural and valuation issues for renewables project
• Represented privately held real estate development business in Tax Court in successfully resolving passive activity loss issues
• Large energy company before Exam and Appeals on deductibility of break-up fee payment made under merger agreement
• Darling Ingredients Inc. v. Smith, (Del. Chancery Ct): secured summary judgment for Darling Ingredients regarding sharing of tax benefits under a stock purchase agreement
• Private equity portfolio company in BBA audit proceeding before IRS Exam
• Major telecommunications company dispute before IRS Appeals regarding former Section 199’s application to computer software
• Large family office before IRS Exam on valuation issues
• Major energy company before IRS Appeals on scope of hedging rules applied to AMT activities
• Oil and gas company before IRS Exam and Appeals on scope of at-risk rules

Prior to joining Kirkland, Leah was involved in the following matters:

Tax Controversy/Litigation

• Major energy company on competent authority and MAP negotiations
• Major energy company on transfer pricing audit relating to intellectual property
• Major telecommunications company on competent authority and MAP negotiations
• Alternative energy company — Investment tax credits
• Energy company — Excise tax issues
• Utility company — Contested rate case before the Texas Public Utility Commission relating to Medicare Part D and other tax issues
• Major energy company — Depreciation issues
• Major oil field services company — Research and development credit issues
• Independent energy company — Handled compensation issues
• Individuals — Valuation issues for charitable deductions
• Individuals — Deductibility of business expenses
• Individuals — Passive activity losses and at-risk partnership rules

Transactional Tax

• Major energy company — Internal spin-off within a U.S. based multinational group
• Oilfield services company — Various upstream oil and gas participations
• Major energy company spin-off transactions
• Major media company spin-off transactions
• Numerous capital markets transactions for public and private companies
• Multiple acquisitions and dispositions involving partnerships, LLCs and S corporations