Image of Shane Milam

Shane Milam

Counsel, New York

“I advise on U.S. tax issues relating to domestic and cross-border transactions, finding creative solutions for challenging tax issues in a variety of different contexts.”

Overview

Professional experience

Education

Published works

Overview

Shane’s practice focusses on a wide range of U.S. and international tax issues for the world’s leading sovereign wealth funds, private equity groups, multinational corporations and financial institutions. Shane regularly advises clients regarding structuring investment funds and managed accounts, corporate mergers and acquisitions, complex financial products, joint ventures, spin-offs and reorganizations, and capital markets and financing transactions. Among other things, Shane has extensive experience advising sovereign wealth funds with regards to issues relating to Section 892 of the U.S. Internal Revenue Code. 

Shane is currently based in New York and has spent four years working in Linklater’s London headquarters.

Work highlights

Shane has advised on some of the market’s largest and most complex deals, including representing: 

  • a major Asian sovereign wealth fund on a variety of substantial and sponsor investor commitments to U.S. and European private equity and infrastructure funds, on establishing managed accounts with several U.S. and European investment managers, and on its investment in the GP of a major pan-European private equity house and its funds.
  • a large European investment manager regarding the restructuring of a US$3bn global real estate fund.
  • Petrobras on the formation of a $1.1bn joint venture with Murphy Oil and its $562mn sale of its Pasadena refinery to Chevron.
  • Marfrig Global Foods on the US$969m acquisition of 51% of National Beef Packing Company and on the US$2.4bn sale of Keystone Foods to Tyson.
  • Visa Europe Ltd. in connection with its US$20bn acquisition by Visa Inc.
  • I Squared on the acquisition of TIP Trailer Services.
  • TDR Capital on numerous acquisitions, dispositions and refinancings involving its portfolio companies, including EFR, Hurtigruten, IMO Group, and Euro Garages.

Professional experience

Shane has been recognized as a leader in the field of taxation by Legal 500 and Super Lawyers and served as the lead draftsperson for a recent International Capital Markets Association initiative to develop a standardized approach to addressing FATCA in international capital markets transactions.

Additional relevant transactions in which Shane has advised include:

  • ASSA ABLOY with respect to several acquisitions, including August Home, KEYper Systems, Luxer One, Pioneer Industries, Amarr Company, Ameristar Fence Products and 4Front Engineered Solutions.
  • Bioceres, a leading Latin American agricultural biotech company, in connection with its acquisition by Union Acquisition Corp., a special purpose acquisition company.
  • bpost, the Belgian Post Group, on its acquisition of Radial, the fulfilment company formerly known as eBay enterprise, for US$820m.
  • a large Canadian pension fund on substantial investor commitments to European private equity funds.
  • a large Middle Eastern sovereign wealth fund on the disposal of a US$2bn portfolio of private equity interests.
  • a large Middle Eastern sovereign wealth fund on cornerstone investor commitments to European private equity and infrastructure funds.
  • a European investment bank in connection with establishing an infrastructure debt fund.
  • Saeta Yield in connection with its initial public offering as the first yieldco to be listed in Europe.

Education

Shane holds a Juris Doctor from the University of Pennsylvania Law School, where he was the Executive Editor of the University of Pennsylvania Journal of International Economic Law. He obtained a certificate in Business and Public Policy from The Wharton School of the University of Pennsylvania and received his undergraduate degree from Whitman College.

Published works

Co-author, “Proposed Regulations Clarify US Federal Income Tax Treatment of Investments by Foreign Governments”, Derivatives Financial Products Report, December 2011