- LL.M. (Taxation)New York University School of Law1985
- J.D.The University of Texas School of Lawwith honors1984
- B.B.A. (Accounting)The University of Texas at Austin1981
David Zimmerman has a sophisticated transactional practice involving a wide range of federal income tax matters relating to mergers and acquisitions, spin-offs, dispositions, corporate reorganizations and financings, with a particular emphasis on corporate tax planning and consolidated return matters. He is regularly engaged as special outside tax counsel for complex corporate transactions, many of which have been recognized for their complexity and scope. Mr. Zimmerman also represents a number of privately held corporations, many of which are very significant in size, and he has an active rulings practice. Mr. Zimmerman also assists clients with audits and negotiating settlements at Appeals.
Mr. Zimmerman was a Graduate Editor of the Tax Law Review at New York University Law School and the Managing Editor of the Texas International Law Journal at the University of Texas Law School.
- Advised an integrated oil and gas company on exchangeable share acquisition of foreign-based target; spin/merger acquisitive transaction of joint venture interest.
- Advised a Fortune 50 company on several multi-billion dollar dispositions of business units.
- Advised a food services company on a multi-billion dollar tax-free spin-off and subsequent merger transaction.
- Advised an oil and gas exploration company on acquisition of shallow water Gulf properties and associated financings.
- Currently advising and implementing various internal restructurings/spin-off transactions involving domestic and international operations for several major utility companies.
- Advised multiple clients on arbitration of disputes arising under tax sharing agreements.
- Represented a foreign-based financial institution before Appeals on application of tax-free reorganization provisions on separation/combination effected under foreign law.
- Chambers USA: Tax (District of Columbia), 2018
- Legal 500: Tax: Non-Contentious, 2015 - 2019
- Legal 500: Tax: International Tax, 2013 - 2015, 2019
- Member, Thomson West Tax Advisory Board
- Member, American Bar Association
- Member, Affiliated and Related Corporations Taxation Committee, American Bar Association
District of Columbia
David Zimmerman was quoted on the IRS's first letter ruling involving the spinoff of a research-intensive business that has yet to generate income.
Layla Asali and David Zimmerman will speak at the Houston Tax Executives Institute (TEI) 2020 Tax School on February 26, 2020, in Houston, Texas.
David Zimmerman commented on the upcoming release of final rules clarifying caps on business interest payment deductions following the passage of the Tax Cuts and Jobs Act of 2017.
Andy Howlett and David Zimmerman commented on what tax practitioners hope the government will address in its final rules on the Tax Cuts and Jobs Act's (TCJA's) new limits on business interest expe
David Zimmerman was quoted on the potential creation of a new regime for Section 355 tax-free spinoffs by the Internal Revenue Service (IRS) and U.S. Department of the Treasury.
On June 14, 2019, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) simultaneously issued proposed regulations (GILTI Proposed Regulations)1 and final regulati
On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
In this article, Layla Asali, Andrew Howlett, Katherine Zhang,* and David Zimmerman discuss Revenue Procedure 2017-52, which describes the Internal Revenue Service's (IRS's) pilot program that expa
On September 21, 2017, the Internal Revenue Service (IRS) introduced a pilot program that expands the scope of letter rulings available for distributions intended to qualify as tax-free spin-offs u