Mr. Davison practices primarily in the areas of taxation of mergers and acquisitions, limited liability companies and S corporations, real estate, exempt organizations and trusts and estates. He has served as lead counsel and as tax counsel in numerous transactions involving public companies and has obtained private letter rulings from the Internal Revenue Service with respect to such transactions. Mr. Davison represented the distributing corporation in the first “cash rich spinoff” about which Robert Willens, a leading tax commentator, publicly stated: “It’s going to be one of the five or six greatest tax transactions ever. It’s never been done before. It’s very bold, very imaginative and very creative.” In transactions involving private companies, his work focuses on the corporate and tax aspects of private equity transactions, including the financing of such transactions.
Mr. Davison has structured and advised limited liability companies with multiple classes of ownership interests, complex allocations of taxable income and loss, and corresponding distribution provisions. In the exempt organization area, Mr. Davison has represented the Greater Kansas City Community Foundation from its inception, two of the 20 largest private foundations in the United States, and two charitable remainder trusts each with assets in excess one billion dollars. He obtained a private letter ruling from the Internal Revenue Service authorizing the Community Foundation to own and operate the Kansas City Royals. He also obtained a private letter ruling from the Internal Revenue Service permitting a CRT to use an offshore subsidiary to avoid unrelated business taxable income.
Mr. Davison has been recognized in Chambers USA, Best Lawyers in America, Missouri “Super Lawyers” and the Kansas City Business Journal Best of the Bar.