AREA OF PRACTICE

Tax

Biography

Nicole Bouchard is a Partner and Practice Group Leader of the Firm's Tax Practice Group. Nicole's practice encompasses general tax planning issues including corporate, partnership, real estate, private equity, hedge fund, and international taxation. Nicole advises her clients on domestic and international mergers and acquisitions, complex financings, cross-border investments, aircraft finance transactions, and tax controversy matters. She works with a variety of specialized entities such as tax-exempt organizations and REITs and provides pro bono representation to several nonprofit organizations.

Additionally, Nicole participates in the representation of creditors, debtors, and investors to restructure, acquire, and sell financially troubled entities inside and outside of Chapter 11 bankruptcy proceedings.

Prior to rejoining Brown Rudnick, Nicole was a Senior Counsel at MetLife where she primarily engaged in tax planning related the company’s alternative investment portfolio. Nicole also provided tax advice with respect to the company’s third-party asset management platform and tax issues specific to insurance companies.

Nicole was named to Law360's Rising Stars list for Tax in 2021. Nicole is recognized by The Legal 500 US and has been named among the leading Bankruptcy Tax Specialists in the Nation’s Major Law Firms by Turnarounds & Workouts magazine.

Awards

Representation

Advising the Coalition of Abused Scouts for Justice in the Chapter 11 bankruptcy case of Boy Scouts of America on tax matters involved in a potential settlement structure for thousands of sexual abuse victims.

Advising the Ad Hoc Committee of consenting Governmental & Other Contingent Litigation Claimants in the bankruptcy cases of Purdue Pharma, In re Purdue Pharma, L.P., with respect to tax matters affecting the settlement framework with Purdue and its shareholders for a proposed consensual plan in the bankruptcy.

Advising Justice John K. Trotter (Ret.), Trustee, and Cathy Yanni, Claims Administrator, of the multibillion-dollar PG&E Fire Victim Trust on multiple aspects of trust administration and asset management, qualified settlement fund tax considerations, claims distribution tax matters, and related compliance with applicable laws.

Advising the Governmental Plaintiffs Ad Hoc Committee in the bankruptcy cases of Mallinckrodt plc, In re Mallinckrodt PLC, with respect to tax matters under a global settlement to resolve opioid-related litigation claims against Mallinckrodt.

Advised gourmet food retailer Dean & DeLuca in its Chapter 11 proceedings.

Advised the Official Committee of Unsecured Creditors of Chesapeake Energy Corp.

Advised the Official Committee of Unsecured Creditors of Ultra Petroleum.

Advised the Official Committee of Unsecured Creditors of Alta Mesa Resources, Inc.

Advised Queensgate Investment LLP in acquiring a U.S.-based group of hotels for approximately $400 million, advising on tax issues associated with the acquisition, financing, and preservation of the historic tax credit structure.

Representation of a public company in a $1 billion private placement of senior notes.

Representation of a UK company in a pre-offering restructuring prior to placing its shares on the AIM.

Representation of a U.S. software company in connection with an internal restructuring related to its intellectual property.

Representation of a large tax-exempt organization in obtaining relief from tax-related penalties.

Representation of multiple foreign clients regarding inbound real estate investment structures.

Representation of multiple clients in the Blockchain and tokenized ecosystems space.

Education

New York University – L.L.M., 2008
Chicago-Kent College of Law – J.D., with honors, 2007
University of Wisconsin, Madison – B.S., 2003

Bar Admissions

New York
Publications
Co-author, "Tax Treatment of Foreign Partners Selling Certain Partnership Interests," Brown Rudnick Alert (December 27, 2018)
Co- author, “Qualified Opportunity Zones,” Brown Rudnick Publication (October 26, 2018)
Co-author, "2017 Tax Reform," Brown Rudnick Alert (December 20, 2017)
Awards and Honors
Law360, Rising Star, 2021
The Legal 500 US, US Taxes: Non-contentious, 2019-2021
Turnarounds & Workouts, Bankruptcy Tax Specialists in the Nation's Major Law Firms, Multiple Years
Community Involvement
New York Junior League
Free Arts NYC Junior Board