Richard J. Wright
Partner
Norton Rose Fulbright US LLP
Related services and key industries
Biography
Richard J. Wright is a partner in Norton Rose Fulbright's tax practice residing in the New York office. His practice often focuses on the tax aspects of complex, high-dollar transactions in diverse industries, including energy, renewable energy, technology, aerospace, airlines, and pharmaceuticals. Richard has also advised foreign governments with respect to debt and equity offerings.
Professional experience
Collapse allLL.M, New York University School of Law, 2003
JD, Brooklyn Law School, 1998
BA, summa cum laude, Phi Beta Kappa, Boston College, 1995
- New York State Bar
- Advised I Squared Capital on the tax aspects of its US$1.2 billion acquisition from Duke Energy of a portfolio of hydroelectric and natural gas generation plants, transmission infrastructure and natural gas processing facilities, totalling 2,300 MW, in Peru, Chile, Ecuador, Guatemala, El Salvador and Argentina.
- Advised I Squared Capital on the tax aspects of its US$1.3 billion acquisition of IC Power's Latin American and Caribbean businesses from Kenon Holdings Ltd.
- Advised L3 Technologies on the tax aspects of its acquisition of software development companies organized in Australia, Canada, the United States and the United Kingdom.
- Negotiated the tax aspects of a Southern Cross fund's acquisition of companies that operated Petrobras's fuel distribution business in Chile.
- Advised a Canadian purchaser on the tax aspects of the acquisition of the shares of TravelBrands USA Stock and assets relating to the Red Label Vacations business.
- Represented Rockwell Collins with respect to the tax aspects of its divestment of certain aerospace products and technologies.
- Represented the Privatization Administration of the Republic of Turkey in its sale of a 23.9 percent stake in Türkiye Halk Bankası A.Ş. via a secondary public offering including a Rule 144A/Regulation S global equity offering. The transaction was the largest capital markets offering of a Turkish issuer to date, with proceeds exceeding US$2.5 billion.
- Advised LATAM Airlines with respect to the tax aspects of the refinancing of 32 Boeing 767-316F aircraft that was effected pursuant to a loan agreement entered into by a subsidiary of LATAM Airlines and a consortium of lenders on June 27, 2018.
- Advised LATAM Airlines with respect to whether a purported sale by the Chirihue Leasing Trust of two Boeing 767-316F aircraft to Platero LLC, an indirect wholly-owned subsidiary of LATAM Airlines, was a true sale or a financing for U.S. federal income tax purposes and whether a related loan made by the owner of the Chirihue Leasing Trust to a Florida branch of LATAM Airlines should be respected as a loan for U.S. federal income tax purposes.
- Advised domestic and foreign airlines with respect to the tax aspects of lease assignments, lease amendments and the exercise of lease purchase options, and with respect to U.S. withholding tax issues, U.S. trade or business issues, "true lease" and economic substance issues, the gross transportation tax, FIRPTA and state and local sales tax issues.
- Advised domestic and foreign lessors and lessees with respect to the U.S. federal income tax implications of sale-leaseback transactions involving wind, solar, fuel cell and transportation property.
- Advised investors with respect to qualification for the investment tax credit, production tax credit and bonus depreciation.
- Rendered tax advice with respect to partnership flip transactions involving utility scale solar projects.
- Advised pharmaceutical clients with respect to stock and asset purchase agreements and licensing, manufacturing, distribution and supply agreements and related U.S. withholding and other tax issues.
- Legal 500 US, Recommended lawyer: US taxes: Non-contentious, The Legal 500, 2024
Insights
Equipment leasing: Tax principles and structuring
Publication | November 02, 2023