Tax Law
Clay A. Littlefield
Recognized in Best Lawyers since 2018 Awarded Practice Areas
Biography
Clay Littlefield, a partner based out of the firm’s Charlotte and New York offices, is a member of the Federal and International Tax group. Clay’s practice concentrates on tax issues confronted by underwriters, issuers and investors participating in structured finance transactions, including mortgage and asset-backed securitizations, REMICs, CLOs, REITs, and similar structures. Clay’s practice also focuses on advising financial institutions on the tax and legal aspects of various structuring alternatives and investment product proposals, as well as providing counsel to U.S. and foreign clients in connection with mergers and acquisitions, distressed asset arrangements and real estate and corporate finance issues.
Prior to joining Alston & Bird, Clay was an attorney with the Internal Revenue Service’s Office of Associate Chief Counsel, Division of Financial Institutions and Products, where he was involved in the review and implementation of the special tax laws applicable to banks and other financial institutions, structured finance and securitization transactions, hedging arrangements and financial derivatives.
Overview
Charlotte, North Carolina
- University of Mississippi, J.D., graduated 1998
- Georgia State University, B.A., graduated 1994
- North Carolina, North Carolina
- Tennessee, Tennessee
- Georgia, Georgia
- Alternative Investment Group of the Carolinas (AIGC) - Member
- American Bar Association - Past Vice-Chair of the Banking & Savings Institutions Committee of the Tax Section
- Structured Finance Industry Group (Tax Section) - Member
- Internal Revenue Service (IRS) - Office of the Commissioner - IRS Chief Counsel
Charlotte, North Carolina
- North Carolina, North Carolina
- Tennessee, Tennessee
- Georgia, Georgia
- Alternative Investment Group of the Carolinas (AIGC) - Member
- American Bar Association - Past Vice-Chair of the Banking & Savings Institutions Committee of the Tax Section
- Structured Finance Industry Group (Tax Section) - Member
- University of Mississippi, J.D., graduated 1998
- Georgia State University, B.A., graduated 1994
- Internal Revenue Service (IRS) - Office of the Commissioner - IRS Chief Counsel
Client Testimonials
Awards & Focus
Recognized in The Best Lawyers in America® 2026 for work in:
- Tax Law
News & Media
Additional Information
Case History
Cases
- Representative Experience
- Counsels clients on federal tax issues arising in the context of securitization arrangements, including REMICs, CLOs, REITs and other asset-backed financings.
- Advises clients on the federal income tax consequences of transactions involving swaps, options, forward and futures contracts, hybrid debt-equity instruments, securities lending, REPOs and various financial derivative products.
- Assists clients in analyzing the various federal tax issues associated with U.S. and foreign domiciled hedge fund and private equity structures and investments.
- Counsels clients on federal tax associated with tax hedge qualification and related timing and character issues.
- Advises clients on the federal tax aspects of taxable and tax-free mergers and acquisitions.
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