Clay Reynolds

is a senior counsel in the Tax Group. Mr. Reynolds spends much of his practice advising on tax issues arising in connection with the formation of (and investment in) private equity and hedge funds, as well tax issues emanating from structured financings, project financings and the acquisition and disposition of assets and companies. In connection with his private equity and hedge fund practice, Mr. Reynolds regularly advises on issues relating to the unrelated business taxable income, effectively connected income, passive foreign investment companies and taxable mortgage pools. Mr. Reynolds has also worked extensively on leveraged lease financings and the restructuring of troubled loans and distressed corporations.

Additionally, Mr. Reynolds has been heavily involved in many of the tax issues emanating from the deregulation of the electric power industry, and advises numerous independent power producers and electrical generating cooperatives (both taxable and tax exempt) on tax issues.