Devon Bodoh
Biography

Devon advises clients on cross-border mergers, acquisitions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, and other tax attributes, and consolidated return matters.
Prior to joining Weil, Devon was the leader of KPMG’s Global Complex Transactions group. He was also the Principal-in-Charge of the Washington National Tax International M&A Group, and a member of KPMG’s global leadership group for International Tax and Deal Advisory (M&A) Tax. He also was Principal-in-Charge of KPMG’s Latin America Markets Tax practice. Prior to joining KPMG in 2010, he was a partner at another major law firm.
Devon is recognized as an expert in Who’s Who Legal: The International Who’s Who of Corporate Tax and as a “Bankruptcy Tax Specialist” by Turnarounds & Workouts magazine. He is also recommended for International Tax by Legal 500 US.
Devon frequently speaks on related subjects for groups including the Practicising Law Institute, International Fiscal Association, DC Bar, Tax Executives Institute, the American Bar Association, the American Institute of Certified Public Accountants, Fundaçao Brasileira de Contabilidade and the Latin Lawyer. He has been an adjunct professor at George Mason University School of Law, and formerly was a member of the Dean's Advisory Board for the University of Detroit School of Law.
Representative Experience**
- Willis Towers Watson PLC in its pending $80 billion combination with Aon PLC and in its $1.3 billion acquisition of TRANZACT.
- SoftBank Group Corp. (SBG) in its agreement to provide $6.5 billion in debt and equity financing to WeWork, to make a $3 billion tender offer to holders of WeWork shares, other than SBG and its affiliates, and in connection with revisions to the WeWork governance structure.
- Churchill Capital Corp IV, a SPAC sponsored by Churchill Capital Group, in its $11.75 billion take-public merger with Lucid Motors.
- Churchill Capital Corp III, a SPAC sponsored by Churchill Capital Group, in its $5.7 billion merger with MultiPlan, Inc. that has an enterprise value based on the transaction of approximately $11 billion.
- Foley Trasimene Acquisition Corp., a SPAC sponsored by Bilcar FT, LP and Trasimene Capital FT, LP., in its pending $7.3 billion combination with Alight Solutions LLC.
- Froneri International Limited (a joint venture between Nestlé and PAI Partners) in its $4 billion acquisition of Dreyer’s Grand Ice Cream Holdings, Inc.
- Sanofi in its $2.5 billion acquisition of Synthorx, Inc.
- Cardtronics plc in its pending $2.5 billion sale to NCR Corporation.
- SiriusXM in its acquisitions of Simplecast, Stitcher and of a minority stake in SoundCloud Ltd.
- Hologic, Inc. in its $159 million acquisition of Diagenode, Inc.
- Westinghouse Electric Company, LLC (a portfolio company of Brookfield Business Partners) in its acquisition of the North American Civil Nuclear Systems and Services Business.
- CPP Investments as a member of a consortium led by EQT in that consortium's $2.7 billion acquisition of Waystar, Inc.
- The Government of the United Kingdom as part of a 50/50 consortium with Bharti Global Limited in the consortium's acquisition, in a chapter 11 court-supervised sale process, of OneWeb Global Limited.
- Ontario Teachers’ Pension Plan (OTPP) in the formation of Trivium Packaging, through a combination of OTPP's portfolio company, Exal Corporation, with the Food & Specialty Metal Packaging business of Ardagh Group and BroadStreet Partners, Inc. in recapitalization transactions involving a new equity investment by affiliates of Century Equity Partners and a $100 million second lien debt and equity investment by affiliates of Penfund Partners.
- H&R Block, Inc. in its $405 million acquisition of Wave Financial Inc.
- Kantar Health, LLC in its $375 million sale by The Kantar Group Limited (a portfolio company of Bain Capital).
- SGS SA in its $335 million sale of Petroleum Service Corporation to Aurora Capital Partners.
- SpeedCast International Limited, and its affiliates, in their chapter 11 cases.
- National Energy & Gas Transmission, Inc. (f/k/a/ PG&E National Energy Group, Inc.) in their chapter 11 proceeding.
- Fiera Infrastructure in its investment in Conterra Ultra Broadband Holdings, Inc. and in, together with APG Group, the acquisition of the equity interests not already owned by Fiera in Conterra Ultra Broadband Holdings, Inc.
- Unidentified co-investors in, together with First Infrastructure Capital Advisors, the acquisition of WhiteWater Midstream, LLC, including, notably, WhiteWater's 60% stake in Agua Blanca from Denham Capital and Ridgemont Equity, and the acquisition of an additional 20% stake in Agua Blanca from WPX Energy.
- Foley Trasimene Acquisition Corp. II, a SPAC sponsored by Trasimene Capital FT, LP II, in its $9 billion merger with Paysafe Group Holdings Limited (n/k/a Paysafe Limited).
- Foley Trasimene Acquisition Corp. II, a SPAC sponsored by Trasimene Capital FT, LP II, in its $1.5 billion initial public offering.
- Foley Trasimene Acquisition Corp., a SPAC sponsored by Bilcar FT, LP and Trasimene Capital FT, LP., in its $1 billion initial public offering.
- Trebia Acquisition Corp., a SPAC sponsored by affiliates of Trasimene Capital Management and Bridgeport Partners organized to acquire target businesses in the financial services, technology, software, data, analytics, services and related industries, in its $518 million initial public offering, together with a $75 million forward purchase agreement with an affiliate of Cannae Holdings, Inc.
- General Electric in its $9.5 billion acquisition of Amersham plc.
- General Electric in its $5 billion sale of GE Americom Communications to Societe Europeene des Satellites (SES).
- KKR Credit, as main creditor to Abengoa SA, in the restructuring of Abengoa SA.
- PG&E in their $9 billion California Utility chapter 11 proceeding.
- Burger King in its acquisition of Tim Hortons and formation of Restaurant Brands International.
- Restaurant Brands International in its acquisition of Popeyes Louisiana Chicken.
- Mosaic corporation in its acquisition of Vale Fertilizantes and its significant Canadian assets.
- The Walt Disney Company in its $6.4 billion acquisition of Pixar.
- The Walt Disney Company in its $5.2 billion acquisition of Fox Family.
- The Walt Disney Company in its $3.8 billion acquisition of Marvel Entertainment, Inc.
- The Walt Disney Company in its $2.7 billion spin-off of ABC Radio and subsequent merger with Citadel Broadcasting Corporation.
- The Walt Disney Company in its acquisition of Muppets.
- Ackerley Group in its $800 million sale to Clear Channel Worldwide.
- Ontario Teachers’ Pension Plan in its acquisition of Imperial Parking Corp.
*Admitted to the D.C. and Michigan Bars only; not admitted in Florida
**Includes matters handled prior to joining Weil.
Awards and Recognition, Speaking Engagements, Latest Thinking, Firm News & Announcements
Awards and Recognition
- Devon Bodoh Recommended for International Tax Award Brief — Legal 500 US
Speaking Engagements
-
Strafford Publications’ Webinar Series
Speaker(s):
Devon Bodoh
March 25, 2021 — Weil International Tax Head Devon Bodoh presented on a panel titled “U.S. Tax Treatment of Hybrid Entities and Transactions: Sections 267A and 245A(e) Regulations” as part of Strafford Publications’ Webinar Series.
-
TEI’s 71st Midyear Conference
Speaker(s):
Devon Bodoh
March 22, 2021 — Weil International Tax Head Devon Bodoh presented on a panel titled “Important Trends in COVID-Era M&A Transactions, Including TRAs, SPACS, and Other Acronyms” as part of TEI’s 71st Midyear Conference.
Latest Thinking
-
International Comparative Legal Guide (ICLG) – USA: Corporate Tax Laws and Regulations 2021
Publication — International Comparative Legal Guides
— By
Devon Bodoh,
Joseph M. Pari and
Lukas Kutilek
— PDF
— December 14, 2020
This chapter first appeared in the International Comparative Legal Guide (ICLG) – Corporate Tax 2021. ...
-
The Treasury Department Releases Final and Proposed PFIC Regulations
Blog Post — Tax Blog
— By
Devon Bodoh and
Greg Featherman
— December 09, 2020
On December 4, 2020, the IRS released final regulations (T.D. 9936) and proposed regulations (REG-111950-20) relating to the modification... ...
-
Brexit & Tax Treaties: U.K. Investors May Lose Treaty Benefits With Respect to U.S. Investments
Blog Post — Tax Blog
— By
Devon Bodoh,
Jenny Doak,
Stuart Pibworth and
Lukas Kutilek
— December 05, 2020
The withdrawal of the United Kingdom (“U.K.”) from the European Union (“E.U.”) may impact certain cross-border organizational structures. ...
- Tax Country Comparative Guide — U.S. Tax Publication | Tax — By Devon Bodoh, Joseph M. Pari, Alfonso J Dulcey and Alexandra Jamel — PDF — October 05, 2020
-
Final Section 864(c)(8) Regulations – Some Relief for Certain Non-U.S. Partners
Blog Post — Tax Blog
— By
Devon Bodoh,
Greg Featherman,
Robert Frastai and
Carlos Parra
— September 25, 2020
On September 21, 2020, the IRS finalized regulations (the “Final Regulations”) under section 864(c)(8) of the Internal Revenue Code (the “Code”). ...
Firm News & Announcements
- Weil Advised Foley Trasimene Acquisition Corp. II in its $9 Billion Merger with Paysafe Deal Brief — March 30, 2021
- Weil Advises Churchill Capital Corp IV in its $11.75 Billion Merger with Lucid Motors Deal Brief — February 22, 2021
- Weil Advises Cardtronics in its Pending $2.5 Billion Sale to NCR Corporation Deal Brief — January 25, 2021
- Weil Advises Foley Trasimene Acquisition Corp. in its Pending $7.3 Billion Merger with Alight Solutions LLC Deal Brief — January 25, 2021
- Weil Advised SiriusXM in its $325M Acquisition of Stitcher Deal Brief — October 19, 2020