Mark H Leeds is a shareholder with the law firm of Greenberg Traurig. At Greenberg, Mark is a member of the Tax and Capital Markets practice groups. Mark's professional practice focuses on the tax consequences of a variety of capital markets products and strategies, including over-the-counter derivative transactions, swaps, tax-exempt derivatives and strategies for efficient utilization of tax attributes, such as net operating losses. Prior to joining Greenberg Traurig, Mark was a Managing Director and Senior Tax Counsel with Deutsche Bank AG in New York. At Deutsche Bank, Mark led the Tax Counsel function within Group Tax of the Americas. Mark is also the editor-in-chief of Derivatives: Financial Products Report, a Thomson/RIA monthly publication.
Prior to joining Deutsche Bank, Mark served as the general counsel of a credit derivative company and, prior to that, Mark was a partner at Deloitte & Touche where he led the Capital Markets Tax Practice. Mark began his professional career as a tax associate, first at Skadden, Arps, Slate, Meagher & Flom and then at Weil, Gotshal & Manges. Mark is a graduate, magna cum laude, of the Boston University School of Law (1984), and holds a Bachelor of Arts, cum laude, from Binghamton University, in Economics (1981). Mark also holds an LLM in taxation from New York University (1990).
Mark is a frequent writer on tax topics affecting the Capital Markets. Some of his recent articles include: When the Cure Could Be Worse than the Ailment: The 'Other Revenue' Provisions of the Health Care Choices Act of 2009 (July 2009); The Future Will Be Better Tomorrow: The Obama Tax Agenda Is Released (May 2009); Providing Certainty on Death and Taxes: IRS Issues Initial Guidance for Sellers and Purchasers of Life Insurance Policies (May 2009); Restructuring of Applicable High Yield Discount Obligations After Passage of the American Recovery and Reinvestment Act of 2009 (February 2009); IRS Slams the Brakes on a Loss Acceleration Strategy: CCA 200849012 Challenges Sophisticated Technique to Recognize Losses on Accounts Receivable (December 2008); The End of Deferral as We Know It: New Law Prohibits Deferral of Compensation Paid to U.S. Managers by Off-Shore Hedge Funds (October 2008); Quick, Easy and Wrong: Congress Considers Legislation to Curtail Energy Trading and the Use of Off-Shore Blockers (August 2008); An IRS Trifecta: Three Public Releases Affecting Hedge Funds and Funds of Funds Issued on One Day (July 2008); A (More) Modest Proposal: Selected Provisions of the Tax Reduction and Reform Act of 2007, (2007); IRS Provides Favorable Guidance on, and Parameters for, Convertible Bond Hedge Issuances, (2007); Convergence Where You'd Least Expect It: The Internal Revenue Service Proposes Foreign Tax Credit Regulations Attacking Double Dip Structures (2007); Giant Steps: Will Total Return Swaps Over On-Shore Hedge Funds Be Treated as Notional Principal Contracts for Federal Income Tax Purposes? (2007); Its Crystal Tide Ever Flowing: The U.S. Revises its REIT Rules to Encourage Capital Flows in the Real Property Sector (2006); The Oracle of Omaha Does it Again: Berkshire Hathaway Correctly Predicts Successful Outcome to DRD Controversy (2005); The Pendulum Swings Back: The IRS Successfully Challenges Loss Shifting in Santa Monica Pictures (June 2005); When the Exotic Embraces the Mundane: The Total Return Swap Business Expands to Bank Loans (March 2005), When Common Sense Failed: The Long Term Capital Holdings Decision and its Implications for Tax Planning (October 2004).