SAM KAYWOOD is a Partner at Alston & Bird LLP in Atlanta and is the Chair of the Federal Income Tax Group and is a member of the International Tax Group.  Sam concentrates his practice on federal income tax and international tax, including cross border M&A and joint ventures, as well as in-bound investments into the U.S.  Sam has worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe and Latin America.  For example, he structured the sale of operations in Ireland, Spain and The Netherlands on behalf of TLC Beatrice.  In addition, he represented LHS Communications Group, Inc. in a $3.5 billion stock exchange with Sema Group, a U.K. publicly traded company.  Sam has also worked on many international technology-related arrangements, including the use of offshore licensing and R&D arrangements.  Sam is particularly active in structuring investments and acquisitions in Latin America, particularly Brazil, Mexico, Argentina and Chile.  Sam has worked with BellSouth Corporation in connection with several of its investments in Brazil.  Additionally, Sam has advised Paragon Trade Brands, Inc., a manufacturer of hygiene and sanitary products, in connection with its investments in Mexico, Brazil and Argentina.  Sam is a frequent author and speaker on international tax topics, including Latin America.  He has spoken to numerous professional organizations, including the International Bar Association, American Bar Association, Tax Section, Tax Executives Institute, Atlanta Tax Forum, Georgia Tax Conference, having given speeches in cities across the country and in several foreign countries.  He is listed in The Best Lawyers in America for his tax expertise and is Chair of the ABA Tax Section Committee on U.S. Affairs of Foreigners and Tax Treaties.  Sam is also active with the International Fiscal Association.  Sam received his J.D. degree, with distinction, in 1986 from Emory University School of Law.  He received his B.S., with distinction, from Boston College.  After college, he spent four years with Arthur Andersen and became a certified public accountant.