The Legal 500

Cleary Gottlieb Steen & Hamilton LLP’s clients confirm very high standards of cross-border tax advice from the New York office, which works closely with the London-based US tax practice and other offices in Europe, Asia and the affiliated office in Argentina. The return of big deals to the market during 2010 kept lawyers in the nine-partner team busy. In two major assignments, the impressively knowledgeable Leslie Samuels provided tax counsel to BHP Billiton in its $40bn all-cash offer to acquire Potash Corporation of Saskatchewan, and Doug Borisky advised Petróleo Brasileiro (Petrobras) in its record-breaking $67bn SEC-registered global equity offering. The Chapter 11 reorganization of Nortel Networks Corporation and its related subsidiaries continued to provide challenges – Jason Factor advised on the sale of several business units, including the sale of substantially all of the assets of Nortel’s Multi Service Switch businesses globally through a bankruptcy auction to Telefonaktiebolaget LM Ericsson, and William McRae represented Nortel in negotiations for the settlement of US federal income tax claims with the IRS, and the settlement of a multibillion-dollar transfer pricing dispute with the IRS and the Canadian tax authorities. The firm has also acted for leading companies including Capital One, American Express, The Stanley Works, VeriSign, Mittal Steel, Credit Suisse and HSBC Securities.

Davis Polk & Wardwell LLP’s New York-based tax attorneys handle a steady flow of instructions with an international element and work closely with colleagues in the global network, which expanded in February 2011 with the opening of a Brazilian office. Most members of the tax practice work flexibly between domestic and cross-border instructions. In recent instructions, Neil Barr advised Deutsche Bank Securities financial adviser to Deutsche Börse AG in connection with its business combination agreement with NYSE Euronext, and Michael Mollerus advised Grupo Financiero Santander and Banco Santander in connection with its acquisition of GE Capital’s Mexican consumer mortgage business, which includes a $2bn retail mortgage portfolio Also recommended are Kathleen Ferrell, who provided tax counsel to Colombian financial group Grupo Aval Acciones y Valores on its $1.9bn acquisition of BAC Credomatic, a Central American banking group, from GE Capital, and Harry Ballan, whose international tax planning clients include Aetna, Bertelsmann, Emerson, EMI, E*TRADE and Julius Baer.

Debevoise & Plimpton’s New York-based tax practice group is ‘very knowledgeable, cutting edge and commercial – terrific quality and responsiveness’. International instructions are handled in close co-operation with the London, Paris and Frankfurt and Asian offices. Practice clients range across industries from airlines to mineral extraction, from banking to insurance, with a strong following of global leaders, private equity managers and investment funds. Gary Friedman, who is ‘technically very strong and provides excellent global advice’, advised Clayton, Dubilier & Rice in its acquisition of a 42.5% stake in global commodity and specialty chemicals distributor Univar, in a sponsored recapitalization transaction valuing Univar at $4.2bn. In New York, Peter Schuur ‘is superb – highly knowledgeable, very creative, can translate tax law into English, and has a unique grasp of US/UK tax issues’. In early 2011, Adele Karig provided tax advice to close Baring Asia Private Equity Fund V, a private equity fund with $2.46bn in investor commitments, making it the largest private equity fund launched in Asia since the GFC. Vadim Mahmoudov, recommended for cross-border fund formation within his broader practice, is ‘extremely responsive and usually gives you solid advice immediately’. Clients recently represented in international transactions by the tax group include American International Group, Altegrity and Providence Equity Partners, General Electric and Reynolds Group.

Skadden, Arps, Slate, Meagher & Flom LLP has ‘world-class thought leaders in international tax planning, which increasingly includes non-US tax advice, and transfer pricing’. The international tax practice, which is instructed in numerous transactions of extreme complexity, is co-ordinated from Washington DC by Paul Oosterhuis and Eric Sensennbrenner, who are ‘outstanding – they bring deep technical knowledge and can also formulate practical, actionable advice’. Also in Washington DC, former international counsel at the Department of Treasury Hal Hicks advises in many major international transactions, including, in June 2010, the Valeant Pharmaceuticals International $3.5bn merger with Biovail Corporation of Canada. Nine US partners specialize in international tax and, as well as Washington DC, are resident in New York, Los Angeles and Chicago. Recommended lawyers in New York include Dean Shulman, who is ‘very knowledgeable while also being pragmatic, and more than capable of going toe-to-toe with other highly-regarded firms’, and the ‘clear thinking’ Diana Lopo. Sally Thurston advised Irish headquartered, NYSE-listed Covidien through the tax aspects of several of its acquisitions and dispositions, including the $2.6bn takeover of ev3 Inc, and Edward Gonzalez, recommended for M&A transactions, advised Energias de Portugal in the $2.9bn acquisition of Horizon Wind Energy from Goldman Sachs. Clients include Seawell Limited, Merck, BNP Paribas, Evraz Group and Seat Pagine Gialle.

Clifford Chance’s New York-centered tax practice is rather smaller than the other leading firms but the international tax service on offer benefits from close and efficient working with teams in other centers in Europe, Asia and the Middle East. Expertise on offer includes transactional advice, private equity, REITs and, increasingly, in international tax planning for global financial services and insurance corporations. Donald Carden is ‘an excellent tax lawyer for complex and highly technical matters’. In a representative recent instruction, Philip Wagman advised Braskem on its acquisition of a chemical business from Sunoco, the first purchase by a Brazilian headquartered multinational of a US operations business. Avrohom Gelber advises in many of the group’s international capital market assignments; Gelber has represented issuers and underwriters in connection with numerous sovereign-debt issuances, including offerings for the Albania, Croatia and Malaysia. Also recommended are David Moldenhauer, Richard Catalano and Christopher Roman. International tax clients include Bank of Nova Scotia, Hertz, Permira and Commerzbank.

Cravath, Swaine & Moore LLP’s tax group ‘demonstrates great technical skills and an ability to deliver under pressure’. The four New York tax partners work at the highest levels of complexity across international and domestic business transactions of all types. Stephen Gordon advised Kraft Foods in connection with the S19.7bn stock-and-cash takeover of Cadbury plc. Michael Schler, ‘one of the smartest tax lawyers in the US, who provides very responsive service’, and Lauren Angelilli have represented Shell International Finance in connection with a series of registered debt offerings, guaranteed by Royal Dutch Shell, to a total value of $12bn. Andrew Needham has ‘great intellect, energy, judgment and a professional and warm personality’; Needham advised China-based WuXi PharmaTech (Cayman) in its agreement to combine with Charles River Laboratories International, in a cash and stock transaction valued at $1.6bn. Recent clients of the practice include Mangas Gaming, Nestlé, Santander Consumer USA and Ineos Group.

Freshfields Bruckhaus Deringer LLP’s US tax practice team is ‘quite thin, with only three partners; despite this, the quality of advice is great, comparable or better than that of much larger firms’. Gregory May, based in Washington DC, heads the lightly leveraged group. Recommended lawyers in New York include Robert Scarborough, whose ‘grasp of the business issues bolsters his ability to deliver accurate and reliable tax advice extremely efficiently’, and counsel Eschi Rahimi-Laridjani, who is ‘an excellent and precise young tax lawyer’. Washington DC-based Claude Stansbury, who provides ‘clear guidance, and timely responses’, advised ConocoPhillips on its $30bn arbitration following Venezuela’s expropriation of two Orinoco heavy crude oil projects, including a novel claim for consequential US tax damages. Clients advised on cross-border matters include ArcLight, ConocoPhillips and British Columbia Investment Management.

Latham & Watkins LLP has ‘the most consistent bench quality of the bigger tax groups’. Nicholas DeNovio chairs the global international tax practice from Washington DC. The department of some 65 lawyers embraces several United States cities, the UK, Germany, France, and Spain. Asian-linked instructions are led from Los Angeles, where Sam Weiner co-chairs the Asian tax practice and transactional tax practice groups. Middle-eastern instructions are generally handled by the New York and London teams. Key partners in New York include David Raab and Jiyeon Lee-Lim, who provided the tax advice when Norsk Hydro acquired Vale SA’s aluminium business. In Washington DC, Joseph Sullivan is recommended for his cross-border M&A expertise, and Chicago-based Joseph Kronsnoble for tax advice in bankruptcies with an international aspect. Recent clients include Linzor Capital Partners, Sonova Holding AG, Yahoo! and Temasek Financial.

Shearman & Sterling LLP’s tax lawyers in the New York and Washington DC offices work with strong teams in France, Germany, and the UK on numerous major cross-border instructions. Clients comment that the group is ‘more proactive than others in the market, and provides honest, comprehensive responses’. Peter Blessing is ‘up with any other tax attorney in the US’, and Douglas McFadyen is ‘able to quickly deconstruct the most complex transactions into their essential elements, identify the relevant tax issues they produce, and explain the important issues’. Larry Bambino advised Cadbury plc through the highly complex takeover by Kraft Foods having previously assisted with the demerger of Cadbury’s North American beverage operations. The tax practice group has also acted for Macquarie Bank, Daimler AG, Thomson Reuters and Vivendi.

Sullivan & Cromwell LLP’s highly rated New York-based tax practice group works closely with lawyers in the firm’s other offices, and has particularly close links with London and Paris, which allows effective co-operation in complex cross-border instructions. In a recent example of seamless international teamwork, David Spitzer worked with a London tax partner to advise Apollo Global Management in its acquisition, with British CVC Capital Partners, of Dutch Brit Insurance Holdings NV, and Ronald Creamer, again working with the London team, provided tax counsel to Aquiline Capital Partners in the acquisition of Conning & Company and its affiliated businesses in the United Kingdom and Ireland from Swiss Re. Andrew Solomon, the managing partner of the firm’s global tax practice divides his time between London and New York. Other clients include Rio Tinto, Electricité de France, Apollo Global Management, and Fiat and Chrysler Group.

Weil, Gotshal & Manges LLP’s 22-partner US tax team, commended for in-depth knowledge and efficient service, ‘sits at the top table in tax’. The group, most of which is based in New York, handles a steady flow of high-value, complex international assignments. The firm’s main strength is in transactional and advisory work, with a particularly strong following in the private equity sector. In New York, recommended lawyers include Mark Hoenig, who recently provided tax advice to General Electric Capital in the sale of its consumer mortgage business in Mexico, including its $2bn consumer mortgage portfolio, to Grupo Financiero Santander Mexico. Kimberly Blanchard acted as tax counsel to the UK-based Man Group in its $1.6bn cash and stock acquisition of US-based asset management firm GLG Partners. In Washington DC, David Bower represented Oak Hill Advisors in connection with a multi-million investment in Avolon Aerospace Limited, an Ireland-based aircraft leasing company. In the same office, Carolyn DuPuy’s practice includes deep knowledge of the foreign tax credit and anti-deferral provisions of the tax code. Patrick Jackman left the firm to join KPMG. Practice clients include Brookfield Asset Management, Lazard, Macquarie and Providence Equity Partners.

White & Case LLP’s ‘reliable, first-class’ US tax practice, with eight partners in New York and smaller groups in Washington DC and Miami, is also represented in Asian and European offices. Although individual lawyers specialize to some extent, the group does not distinguish the domestic and international. The tax group also self-generates approximately one third of its own instructions as well as providing expert support to other departments. New York-based global tax chief William Dantzler, and Sang Ji, ‘apart from possessing excellent US tax knowledge, are responsive, commercial and pro active – you feel that they are truly part of your team’. James Hayden, who is ‘responsive, technical, experienced and practical’, is recommended for cross-border leasing and aircraft finance. David Dreier advised Mexican chemical producer Mexichem Flúor in its $350m acquisition of the fluoro-chemical business division of INEOS Holdings. Washington DC-based Bruce Davis provides tax advice to Coca-Cola on virtually all aspects of its worldwide business, including numerous acquisitions, divestments and joint ventures. The tax practice group has advised Calpine, Saudi Aramco, WIND Telecomunicazioni and Conoco Phillips.

Baker & McKenzie has now provided tax support to international business for over 60 years. The firm’s tax planning group comprises some 150 attorneys and economists in nine US, and five foreign offices, of whom approximately half major in international tax. The group has deservedly established a reputation for transfer pricing expertise, and contributes to current policy development in the area; Carol Dunahoo and Palo Alto-based Gary Sprague are members of the OECD Fiscal Affairs Committee’s Governmental Working Parties on treaty and transfer pricing matters. Several members of the department have served in senior government positions, including Leonard Terr, and Duane Webber, who now serve as Boeing’s main outside tax counsel, advising on worldwide tax matters, including international integration of acquisitions, tax compliance and planning. The firm has gradually increased penetration of the wider transactions and international structuring market. In recent deals led from New York, Robert DeJoy provided domestic and international tax advice in the structuring of Abbott Laboratories’ $7.1bn acquisition of Solvay’s pharmaceutical business, and Jonathan Stevens advised Johnson & Johnson through an agreement to acquire the balance of equity not already held in Netherlands-based Crucell NV. Also in New York, Marc Levey chairs the firm’s global transfer pricing committee. Chicago-based Gregg Lemein combines his client-commended tax planning and controversy practice to great effect. All partners named practice from Washington DC unless otherwise indicated. Practice clients include Digital River, Facebook, Microsoft and Southwest Airlines.

Caplin & Drysdale is highly recommended for ‘high-value, specialty work’, led by expert partners. One client comments, ‘the weakness of the firm – if indeed there is one – is that, like all boutiques, they do not have a deep bench of associates for the rare matter where you may need more staffing’. The international tax practice of some 14 lawyers of covers all issues from controversy with cross-border elements to high-value transactions, with particular skills in transfer pricing and advance pricing negotiations. David Rosenbloom is ‘quick and knowledgeable’, and Patricia Lewis is ‘very knowledgeable and very conscientious’. Lucy Lee, who has particular expertise in the Korea/Us Double Tax Convention, was recently promoted to partner; Lee worked with other members of the team including Michael Pfeifer to satisfactorily resolve an IRS audit into the affairs of a foreign athlete by elevating the case to competent authority level – the key matter in dispute was which jurisdiction had taxing rights over sponsorship income.

Dechert LLP’s international tax practice group, including European offices, has some 30 fee-earners. The US tax lawyers, who provide ‘a great quality of service’, practice from the Philadelphia, New York and Boston offices. The firm’s strong connections in the private equity sector create a steady cross-border deal flow and the practice also attracts multi-jurisdictional restructuring work. Philadelphia-based practice chair Edward Lemanowicz is ‘an outstanding international tax professional’. Richard Wild and Boston’s Adrienne Baker can both ‘speak off the cuff at length on technical topics, in addition to providing timely written advice that is well-researched and on point’, and Daniel Dunn in New York is ‘a highly creative, ethical and careful lawyer who explains issues, risks and opportunities clearly’. Practice clients include Carlyle Group, Elliott Associates, Arclin and Bayou Hedge Funds.

Dewey & LeBoeuf LLP has ‘the best combination of technical tax knowledge and real-life deal experience’. In international as in domestic tax instructions, the group regularly provides clients with structuring and planning advice on complex corporate transactions, including mergers, acquisitions, spin-offs, restructurings, sales and dispositions, and post-merger integration. In a recent instruction, New York-housed practice head Gordon Warnke, and Arthur Hazlitt joined with Washington DC-based Abraham ‘Hap’ Shashy andJoseph Pari, to advise EnCana on the US tax aspects of the spin-off of its integrated oil business in a complex transaction structured to be tax free in both Canada and the US. The group’s clients include Cenovus, Macquarie, Molson Coors Brewing and Walt Disney.

Gibson Dunn’s tax practice group numbers some 30 lawyers with the majority of the US team based in New York, Washington DC and Los Angeles. The international tax lawyers have attracted a strong following and, in addition to serving on multi-practice teams on larger deals, have built an advisory practice and several areas of niche expertise including the taxation of Sharia-compliant investment vehicles. Recommended lawyers in the group include Washington DC-based practice group chair Arthur Pasternak, who specializes in cross-border corporate and real estate work. Jeffrey Trinklein has provided tax advice to the Kuwait Investment Authority on numerous matters including a $1bn investment in the preferred shares of Dow Chemical Company. Also in New York, David Rosenauer and Romina Weiss specialize in private equity transactions, and have handled numerous complex cross-border transactions. Practice clients include Heineken, CVC Venture, Credit Suisse Alternative Investments and Arcapita Bank.

Linklaters’ New York tax group is ‘at least as good as any other US office of a UK law firm’; the ‘practice is somewhat narrower than that of some of the larger US firms but within its practice areas, it is first rate’. The team is headed by Stephen Land, who is ‘an excellent lawyer – very smart and who has excellent judgment’. The firm’s métier is in major transactional matters and corporate finance, with a bias to cross-border work, and a blue-chip client following which includes JPMorgan Chase, Lloyds Banking Group, Royal Bank of Scotland and CVC Capital Partners. The 11-fee-earner group works tightly with other offices in the worldwide network, as evidenced by a recent instruction, in which Francisco Duque advised BP on the US tax aspects its acquisition of oil and gas properties in Brazil, Azerbaijan and the Gulf of Mexico from Devon Energy, a $7bn deal which was executed in 10 days. The team also advised Sino-Forest Corporation on its acquisition of Mandra Forestry Holdings Limited and the concurrent exchange of guaranteed senior notes. Associate Matthew Welsh leads the group’s work for KKR.

Mayer Brown’s worldwide complement of tax lawyers, most of who are US-based, includes 70 specializing in transactions and planning, and a further 55 in controversy and transfer pricing. Overseas, Paris is the flagship European office although the German offering is also strong. The 2009 ‘alliance’ formed with the Brazilian law firm Tauil & Chequer Advogados in association with Mayer Brown LLP is expected to develop into a full merger in the short term. Washington DC-based Kenneth Klein, who heads the global tax transactions and planning department, worked with Rafic Barrage on major recent assignment to advise in the multibillion-dollar acquisition of pan-European company by US multinational. Chicago residents James Barry and George Craven are both highly recommended and within wider practices, add tax expertise to insurance sector instructions. Jonathan Sambur in Washington DC is recommended for offshore disclosure program instructions. The transfer pricing practice is mentioned in the tax controversy section. Clients recently provided with cross-border tax advice include Norwegian Cruise Line, Carlyle Group and United Parcel Service.

McDermott Will & Emery LLP fields ‘an excellent international tax practice led by Lowell Yoder , who is in a class by himself in the international tax arena’. The firm has some 40 lawyers in the global tax practice, and 30 in the US practicing substantially in international tax from Silicon Valley, Washington DC, Chicago and New York, offering transactional support, tax planning, and international restructuring. In recent instructions, Chicago-based Yoder and members of the team, working with overseas offices, advised a major international company on restructuring European trading operations, and on a $5bn cross-border financing. Also in Chicago, Sandra McGill, who recently advised a large tax-exempt company on the restructuring of its foreign operations, ‘is extremely intelligent and skilled, and has outstanding client service skills’ in her international tax planning practice. Thomas Jones and Barry Quirke are also highly recommended members of the Chicago group. In Washington DC, Philip McCarty is ‘very strong on technical issues’, in large business and partnership cross-border taxation; Michael Kelleher is ‘thoughtful and thorough in all transfer pricing matters’; David Noren is ‘a tax technical genius on almost all international tax matters’; and James Riedy is ‘a guru in US international tax’. New York-based Kumar Paul ‘grasps commercial issues very quickly and provides excellent advice within very short time windows’. Clients include AstraZeneca, Avon, Dun & Bradstreet, Equity International, General Mills, Hoffman La Roche, and Johnson & Johnson.

Paul, Weiss, Rifkind, Wharton & Garrison LLP’s New York-based US tax lawyers are ‘savvy, sophisticated and practical, and very well versed on international tax issues’, and work closely with the London, Tokyo, Hong Kong and Beijing offices, expertly handling M&A transactions and multinational restructuring. Tax department co-chair Richard Bronstein is ‘a leader in the field; he has the ability to assess risk, and is very creative in structuring and driving value’. In a recent instruction, a team led by Jeff Samuels acted as international tax counsel to Shanghai Shendi Group, a new company set by the Shanghai government, in its joint venture contract with the Walt Disney Company to build its first mainland China theme park. David Sicular is recommended for his knowledge of the Canadian tax system and the US/Canada tax treaty. Clients include Viacom, Time Warner, Harbinger Capital and Discovery Communications.

Baker Botts L.L.P.’s international tax work is handled mainly by three Houston partners, each of whom brings wider business expertise to the table. The firm’s strong position in the global energy sector, particularly in oil and gas, has stimulated tax expertise to match and the department is instructed in numerous transactions and financing deals. In recent instructions, Benjamin Wells, ‘an exceptional tax resource’, and Derek Green represented oilfield services giant Schlumberger its complex merger with Smith International, a deal with a value of $11bn, and advised international offshore contractor Transocean through a $2bn senior notes offering. The team works closely with lawyers in other offices in the Middle East, Asia, Russia and Azerbaijan. Clients recently represented in international tax matters include Noble Corporation, Total and Gazprom.

Bingham McCutchen LLP has five partners who specialize in international tax and provide comprehensive transactional support and advisory services to leading corporations, financial institutions and investment funds. The strongest concentration of talent is in Washington DC, where Scott Farmer is recommended for inward and outward investment and is particularly expert in the life sciences sector and Gary Huffman is praised for oil and gas taxation advice. John Magee, who leads transfer pricing group, represented GlaxoSmithKline, in the largest ever transfer pricing dispute, which settled at $3.1bn. Clients include Dow Chemical, Sears Roebuck, Credit Suisse, Deutsche Bank and GE Capital.

DLA Piper LLP’s David Colker leads the global international tax group from Palo Alto, with US representation at partner level in Palo Alto, New York, where a European desk has been established, Washington DC, and more recently, Boston. The international tax group provides wide-ranging services through its global network, and has particularly strong links to the Chinese offices. The department expanded during 2010 with the lateral hire of two experienced partners. Recommended lawyers include Alan Granwell, in Washington DC, who is ‘very efficient and has excellent contacts in the IRS and US Treasury’ for planning and advance pricing agreements; Sang Kim ‘a very strong tax advisor’ with an excellent track record in post-merger integration; and Michael Lebovitz in Los Angeles for international tax planning and transactions. Members of the group recently advised Trident Microsystems in a definitive agreement with Netherlands-headquartered NXP Semiconductors, in which Trident acquired NXP’s television systems and set-top box business lines.

Greenberg Traurig LLP’s Mary Voce chairs the firm’s international tax group from New York, which houses several highly recommended attorneys practising in cross-border work. Seth Entin is ‘an excellent tax attorney who provides very precise, business-oriented advice’, and Ozzie Schindler ‘gives advice a business-person can use, and is obsessed with responsiveness’. The firm, which handles instructions in co-operation with other offices in the domestic network, and branches in Europe and Asia, has ‘a unique knowledge of the Latin American region’.

Kirkland & Ellis LLP’s strong private equity following continues to provide complex and challenging cross-border instructions. The US tax partners regularly contribute to the multi-practice, multi-jurisdiction teams with colleagues from the global offices in London, Munich, Hong Kong and Shanghai. The tax group has considerable expertise in transactional and finance issues as well as tax planning, IRS private rulings and transfer pricing disputes. Most of the firm’s tax partners handle inward investment work, while the more complex assignments are dealt with by specialists including New York-based Steven Clemens, Kevin Treesh and Patrick Gallagher, who represented Avista Capital Partners in its $780m carve-out acquisition of the global auto business of Cloros; the deal closed in December 2010. Recent international tax instructions have been received from Charter Hall Group, Constellation Energy and CVC Capital Partners.

Morrison & Foerster LLP has established a healthy presence in Asian markets and West Coast members of the tax department frequently handle cross-border assignments with colleagues in well-established offices in Tokyo, Hong Kong, Shanghai and Beijing. In a 2010 instruction, Joseph Fletcher advised listed ON Semiconductor when it acquired Sanyo Semiconductor in the first-ever acquisition of a major Japanese technology company by a US company. Practice clients include Gemini Mobile Technologies, the Clorox Company and Topica Pharmaceuticals.

Paul, Hastings, Janofsky & Walker LLP is recommended for ‘heavy duty international tax advisory work’. The firm is particularly well-connected in the financial sector and attracts a steady flow of transactional instructions with European and Asian components. In recent instructions, Orange County-based Douglas Schaaf advised China’s Sino Ocean Land Holdings on the US tax aspects of a $900m Singapore-listed convertible debt offering, and Michael Haun worked with Joseph Kim in the firm’s Tokyo office to advise Korea East-West Power (EWP) in its acquisition of Marubeni Sustainable Energy, a leading US integrated energy company. Alexander Lee, who divides his time between Los Angeles and San Diego, is strongly followed for his work in Asian markets. The Washington DC office lost Rob Culbertson and Kurt Baca to Covington & Burling LLP. New York’s Andrew Short is more commonly found on international work with a European element; he recently provided tax advice on matters including the US-Ireland double tax treaty to two funds, Avolon Aerospace Leasing and Deucalion MC Engine Leasing, for a combined capital rise in excess of $1bn. The firm’s international tax clients include Citigroup Global Markets Asia, Deutsche Bank, Paladin Capital and Threadneedle.

Sutherland Asbill & Brennan LLP’s international tax specialists won one of 2010’s major mandates when a team including Clifford Muller and J Randall Buchanan served as tax counsel to Kraft Foods in its $19.6bn acquisition of UK headquartered Cadbury plc. Robert Chase, who served on the Kraft Foods team, also advised Tyco Electronics in its $1.25bn acquisition of ADC.

Vinson & Elkins L.L.P. strong following of oil and gas clients generates numerous international tax challenges; in recent instructions, Edward Osterberg, of counsel in Houston, provided tax advice to Norway’s Statoil on a joint venture with Sinochem Group, which paid $3bn to Statoil ASA for 40% of the Brazilian offshore Peregrino field. Timothy Devetski, who provides ‘clear to understand, jargon-free advice’, is assisting Apache Corporation’s Canadian subsidiary, which owns a 51% stake in the planned Kitimat liquefied natural gas export terminal in British Columbia. Clients include BG Group and Niska Gas Storage Partners.

Covington & Burling LLP’s lateral hire of the highly experienced and knowledgeable Robert Culbertson, ‘tremendous technical expertise and a wonderful person to work with’, and the ‘solid international tax expert’ Kurt Baca from Paul, Hastings, Janofsky & Walker LLP adds gravitas to a group whose younger partners have achieved a growing prominence. Daniel Luchsinger recently advised in the restructuring and integration of a multibillion-dollar worldwide acquisition into an existing multinational ownership structure. Practice clients include Armani, Bacardi and Vivendi.

Kramer Levin Naftalis & Frankel LLP’s tax group, led by New York-based Howard Rothman, is recommended for partnership, private corporation, and individual international tax planning and structuring. Barry Herzog represented Scientific Games Corporation in connection with structuring a large, complex international joint venture, and John Novogrod advised a US citizen resident in Europe on the tax-efficient divestiture of business interests involving the creation of grantor retained annuity trusts (GRATs) and other entities.

Sidley Austin LLP has built on a solid domestic tax offering to develop a cross-border practice capable of handling complex transactions with a European element. The global tax group is led by Chicago-based Sharp Sorensen, who, working with partners in the US and London, led the tax work on the eBay’s sale of Skype. Laura Barzilai and Paul Wysocki in the New York office are also highly experienced in international transactions.

Simpson Thacher & Bartlett LLP’s New York-based tax group houses the highly rated Robert Holo, who ‘has a broad overall tax knowledge and the ability to render practical advice’. The team recently advised RBS in the sale by RBS Sempra Commodities, a joint venture with Sempra Energy, of its metals, oil and European energy business lines to JPMorgan for a total cash consideration of $1.6bn. Gary Mandel, a ‘creative thinker, adept at devising solutions to complex problems’, assisted Blackstone Group with its investment of ¥1.6bn in eMobile.

Steptoe & Johnson LLP’s Washington DC tax group, headed by Philip West and Mark Silverman, is instructed in a range of international matters, including advice to multinationals on US tax treaty issues and the US tax consequences of internal restructurings. The group has assisted Canada’s TD Bank with a number of international transactional, policy, and controversy matters, including legislative and administrative advocacy in connection with various tax treaties.