Zachary drafts and edits tax disclosures and provisions in Private Placement Memoranda, partnership and LLC agreements for both main fund and co-invest private equity funds, offering circulars, and other agreements. Zachary assists with fund formations and operational issues and analyzes offshore tax structures for efficiency with regard to Subpart F/CFC status as well as PFIC reporting. He advises on transaction structures to minimize deemed dividend inclusions, permanent establishments and withholding taxes.
Before joining Faegre Baker Daniels, Zachary clerked at the U.S. Tax Court. During law school, Zachary clerked for the Minnesota Department of Revenue and worked as a judicial extern at the Minnesota Tax Court. He also served as a Legal Fellow in Rome, where he researched issues related to the Foreign Account Tax Compliance Act (FATCA), trusts, wills, corporate governance and international human rights.