Biography
Theo Agbi is an associate in Weil’s Tax Department and is based in Miami. Theo participates in the representation of Firm clients with respect to the tax aspects of a wide range of corporate transactions.
Theo has been part of the teams advising on the following matters:
- CIIG Merger Corp II in connection with its merger with Zapp Electric Vehicles
- Ember SPV I Purchaser Inc. (an entity controlled by funds managed by Ember Infrastructure Management, LP) in its acquisition, alongside IQ and CDPQ, of H2O Innovation Inc.
- OMERS Private Equity Inc. in its $530 million senior term loan and revolving facilities for Auxey Bidco Limited
- Ontario Teachers' Pension Plan Board and its portfolio company APCO Holdings in its acquisition of National Auto Care
Theo received his J.D., magna cum laude, from Vermont Law School, his DJCE (Diplôme Juriste Conseil d’Entreprise) from CY Université and his B.A. from Amherst College.
Latest Thinking
Latest Thinking
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Notice 2024-16: Guidance Allowing for Basis Adjustments to CFC Stock Transferred in Inbound Nonrecognition Transactions
Blog Post — Tax Blog
— By
Devon Bodoh,
Greg Featherman,
Theo Agbi and
Marvin Zanders
— January 04, 2024
On December 28, 2023, the Internal Revenue Service released Notice 2024-16 announcing the intent of the Treasury Department and the IRS to issue proposed regulations addressing basis consequences under Section 961(c)[1] relating to certain inbound liquidations and asset reorganizations whereby a U.S. corporation acquires from a first-tier controlled foreign corporation all the stock of a second-tier controlled foreign corporation. ...
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Examining the U.S. – Chile Tax Treaty
Blog Post — Tax Blog
— By
Devon Bodoh,
Allen Lalanne and
Theo Agbi
— January 03, 2024
On December 19, 2023, the United States Department of the Treasury announced the entry into force of the tax treaty between the United States and Chile. Originally signed by the United States and Chile on February 4, 2010, the Treaty was approved by Chilean government in 2015 and was ratified by the United States Senate and signed by President Biden on June 22, 2023. ...
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IRS Issues Guidance on Foreign Tax Credit and Global Minimum Tax
Blog Post — Tax Blog
— By
Devon Bodoh,
Greg Featherman,
Jonathan Vita and
Theo Agbi
— December 21, 2023
On December 11, 2023, the Internal Revenue Service released Notice 2023-80 establishing the intentions of the Treasury Department and the IRS to issue proposed regulations addressing the application of the foreign tax credit rules and dual consolidated loss rules with respect to certain taxes under the Pillar Two global anti-base erosion rules. ...