Clay A. Littlefield

Firm: Alston & Bird
Location: Charlotte - NC

  • One South at The Plaza
    101 South Tryon Street Suite 4000
    Charlotte, NC 28280-4000
  • Tel : 704 444 1000
  • Fax : 704 444 1111

Clay Littlefield, a partner based out of Alston & Bird’s Charlotte and New York offices, is a member of the Federal & International Tax Group. Clay concentrates his practice 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 also focuses his practice 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 mergers and acquisitions, distressed asset arrangements, and real estate and corporate finance issues. He is ranked in Chambers USA: America’s Leading Lawyers for Business in Tax for North Carolina and has been consistently recognized by The Best Lawyers in America© in Tax Law.

Before joining Alston & Bird, Clay worked in the Division of Financial Institutions and Products of the Internal Revenue Service’s Office of Associate Chief Counsel, where he was involved in the review and implementation of the tax laws applicable to banks and other financial institutions, structured finance and securitization transactions, hedging arrangements, and financial derivatives.

Bar Admissions

  •  North Carolina
  •  Tennessee
  •  Georgia


  •  Georgetown University (LL.M. Taxation, 2004)
  •  University of Mississippi (J.D., 1998)
  •  Georgia State University (B.A., 1994)


  • American Bar Association, Banking & Savings Institutions Committee of the Tax Section, past vice-chair
  • Structured Finance Association, Tax Section
  • Alternative Investment Group of the Carolinas (AIGC


  • Counsels clients on federal tax issues involving 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 the structuring and implementation of various cross-border structured financing transactions.
  • Advises clients on the REMIC tax implications of making various modifications to residential and commercial mortgage loans and/or liquidating certain REMIC portfolios.
  • 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.

Alston & Bird

Your tax needs are growing progressively more complicated, touching your organization in many ways. It’s vital to have the right team of experienced lawyers to solve knotty problems and develop an overall strategy.

The tax lawyers at Alston & Bird advise the firm’s transactional clients as well as those who turn to us for specific tax representation. We help Fortune 100 companies, startups, and exempt foundations, among other clients. As U.S. News – Best Law Firms 2020 “Law Firm of the Year” in Tax Law, our creative strategies produce the results you need on international, federal, state, and local matters.

From business transactions and dispute resolution to tax legislation and regulatory services, our time-tested lawyers work with you to ensure we’re positioning you for success.

We are truly global. We manage cross-border matters through our international lawyers and an established network of firms around the world. When you need transfer pricing guidance for transactions with foreign affiliates, we provide economic and legal analysis and finely crafted agreements and submissions to U.S. and foreign tax authorities.

Domestically, we handle federalstate, and local tax issues, including planning and unclaimed property and escheat matters. Employers and providers of employee benefits and executive compensation depend on us for both transactional work as well as ERISA litigation. Our unique multidisciplinary method can resolve even your toughest challenges.

Many of our clients consider how to change tax rules from the ground up. Trust our bipartisan tax regulatory lawyers to provide practical policy, political, and technical tax perspectives to help you achieve your goals.

When tax controversies are unavoidable, you can depend on our national team of true tax litigators who represent clients on U.S. and international audits, administrative appeals, trial and appellate litigation, and mediation.

When you need to tackle tax problems, our lawyers provide you with the information and guidance you need to thrive.