The Legal 500

Cleary Gottlieb Steen & Hamilton LLP’s New York office works closely with its London-based US tax practice as well as other offices in Europe, Asia and an affiliated office in Argentina. Jason Factor led the firm’s advice to Nortel Networks Corporation in connection with tax aspects of asset sales in transactions generating nearly $8bn in proceeds for various Nortel estates located in the US, Canada, and Europe, including the $282m sale of Nortel’s Carrier VoIP and Application Solutions business, including units in North America, the Carribean, Latin America, Asia, Europe, the Middle East and Africa to US-based Genband, and the sale of Nortel’s wireless infrastructure assets through a bankruptcy auction to Ericsson for $1.13bn. Erika Nijenhuis led the firm’s advice to Credit Suisse, Deutsche Bank and UBS on an exchange offer and related consent solicitations by Bank of Ireland Group. Nijenhuis also advised Commerzbank on US tax aspects of an €11bn offering of Conditional Mandatory Exchangeable Notes and stock rights.

Davis Polk & Wardwell LLP’s practice advises on all manner of international tax including group planning for multinationals, cross-border acquisitions, reorganiszations and joint venrures, post-acquistiions integration planning, inbound oand outbound investments, international capital market transactions, derivatives and financial products, expatriation transactions and cross border investment management structures and also handles international tax controversies. Sarah Joy recently provided tax advice to Credit Suisse Securities (USA), HSBC, Merrill Lynch, Pierce, Fenner & Smith, RBS and Daewoo Securities as underwriters in connection with a Schedule B debt offering by Korea Finance Corporation of $750m of its 4.625% notes due 2021. Michael Mollerus led the team which advised Banco Santander Chile, as issuers, and Teatinos Siglo XXI Inversiones, as selling shareholder, on the secondary offering by the selling shareholder of 9,725,000 Anerican Depositary Shares, representing 10,104,275,000 shares of common stock, of Banco Santander Chile, for an aggregate price of $650m

Debevoise & Plimpton global tax department chair Burt Rosen leads a team of some 50 lawyers spanning offices in New York, London, Paris and Frankfurt with particular expertise in the financial products tax space. The firm’s lawyers work closely with clients and investment banks on cross-border M&A, private equity, hedge fund formations, joint ventures, bankruptcies and restructurings, public and private financings and real estate transactions to clients in a diverse range of industries including airlines, banking, communications and media, energy, insurance and mining. Seth Rosen led the firm’s tax advice to American International Group in connection with AIA Group Limited’s spin-off from and $20.51bn IPO and listing in Hong Kong, the largest IPO in Hong Kong and the world’s largest IPO in the insurance sector at that time. David Schnabel and Rosen led the tax advice to Reynolds Group in a series of acquisitions and financings totalling more than $15.9bn, including acquisitions of Graham Packaging Company, Pactiv Corporation, Reynolds Consumer Products and Closure Systems International and Evergreen group of companies. Representative clients include Carlyle Group, Mitsui, Pernod Ricard and Verizon.

Skadden, Arps, Slate, Meagher & Flom LLP handles strategic tax planning and tax implementation in multi-jurisdictional cross-border transactions and controversies including transfer pricing and competent authority matters. The firm provides domestic and international tax advice in Europe and the US from its offices in Washington DC, New York, Los Angeles, Chicago, London and Paris. Chicago-based David Levy advised Capital Shopping Centres Group in connection with its $600m REIT joint venture with Equity One, involving a DownREIT joint venture structure to enable Capital Shopping Centres Group to transfer its US real estate subsidiary in a tax-free transaction in one of the first transactions of its kind. The firm advised Sara Lee in connection with the tax-free spin-off of its international coffee and tea businesses via a proposed IPO. Steven Matays advised Burger King Holdings with respect to tax aspects of its $4bn acquisition by 3G Capital Management, a private equity firm backed by Brazilian investors. Practice clients include American Express, BHP Billiton, Chicago Mercantile Exchange and Her Majesty’s Treasury.

Sullivan & Cromwell LLP’s highly regarded tax practice group (‘very strong team, huge resource base, extremely deep knowledge’), led by managing partner Andrew Solomon, who has a ‘deep knowledge of international tax’, works closely with offices across Europe and Asia-Pacific; nearly 50 US, French and UK tax lawyers are located in London, New York, Washington DC and Paris. Andrew Mason recently advised AT&T on tax aspects of its $39bn acquisition of T-Mobile USA from Deutsche Telekom, Ronald Creamer advised China Investment Corporation (as part of a consortium of equity investors) in the $1bn investment in Diamond S Shipping towards the acquisition of 30 medium-range refined product carriers from Cido Tanker Holding.

Clifford Chance’s modest, New York-centered international tax practice benefits from its close and efficient working relationship with teams in the firm’s other offices in Europe, Asia and the Middle East. It represents major foreign and domestic issuers and underwriters in connection with structuring, negotiating and disclosing the tax consequences of a broad range of securities, including advising on offerings, negotiating tax provisions and reviewing tax structures for significant foreign and domestic lenders. The firm recently represented FIBRA Uno, Mexico’s first REIT, in a Mexican IPO and an international private placement of trust securities, and acted for Gavea in connection with Arcos Dorados’ IPO and pre-IPO restructuring. It also advised Volkswagen in connection with structuring its proposed merger with Porsche Automobil Holding. Notable clients include Deutche Bank, Swiss Re and Partners Group.

Cravath, Swaine & Moore LLP’s four tax partners in New York, led by Stephen Gordon, frequently have central roles in large international corporate transactions involving cross-border M&A, and the team has developed innovative financing structures both in US and international markets. Michael Schler led the firm’s advice to BAE Systems on the tax aspects of its Luxembourg Stock Exchanged-listed $1.25bn debt offering, and represented the initial purchasers (Goldman Sachs International, Deutsche Bank, ING and Morgan Stanley) in connection with the €500m high-yield senior secured debt offering of Kabel Deutschland. Practice clients include Time Warner, Shell and Sovereign Bankcorp.

Gregory May heads up a truly multi-jurisdictional and international three-partner practice at Freshfields Bruckhaus Deringer LLP that operates as part of a global tax department working interactively across jurisdictions. The bulk of the firm’s work in New York and Washington DC is corporate, ranging from supporting public M&A to private equity transactions, as well as advising on international tax aspects in a high-volume of complex finance work such as securities offerings, bespoke transactions and international arbitrage transactions. The firm recently handled two significant transactions for Travelex involving that company’s global business, and restructured a group of previous CLO/CDO transactions to take advantage of lower interest rates on behalf of UBS. Other active clients include Société Générale, ArcLight Capital Partners, Alinda Capital Parners and One Equity Partners.

Washington DC-based Nicholas DeNovio chairs the Latham & Watkins LLP global international tax practice of some 70 lawyers across the US, UK, Germany, France, Spain and Singapore. Sam Weiner co-chairs the Asian practice from Los Angeles, while New York and London teams generally handle middle-eastern instructions. The firm assists US taxpayers to structure their offshore activities and non-US taxpayers in structuring their operations within the US. Cheryl Coe and Lisa Watts recently advised the Carlyle Group regarding the tax aspects of its $900m joint venture with the Tiger Group, in partnership with the Seaspan Corporation, the Washington Family, Gerry Wang and Graham Porter to invest in maritime shipping vessels primarily strategic to China, Hong Kong, Taiwan and Macau. Practice clients include Broadcom Corporation, One Equity Partners, Intesa Sanpaolo and Goldman Sachs.

Teams in France, Germany and the UK complement Shearman & Sterling LLP’s New York and Washington DC offices to cover the high-volume of cross-border financing and restructuring, mainly for private companies. The firm, which provides ‘a quality work product’, is consistently increasing its role in sovereign wealth across Asia and in the Middle East. The Palo Alto office is very active in the Chinese market, recently advising the underwriters, led by Morgan Stanley, Deutsche Bank and Credit Suisse, in connection with the $855m NYSE IPO by Renren, one of the biggest social networking companies in China. The firm also recently represented Marriott International on US tax matters relating to a $1bn plan to split the company’s business into two separate publicly traded companies. Practice clients include China Fire & Security Group, Francisco Partners and Bain Capital. Douglas McFadyen and Lawrence Bambino are ‘particularly good’.

The greatest concentration of talent within Weil, Gotshal & Manges LLP’s 22-partner US international tax team is located in New York and supported by lawyers in the firms network of 20 offices across the US, Europe and Asia. The group handles transactional and advisory work, with particular expertise in the private equity space. Scott Sontag and Amy Rubin in New York and Joanne Etherton in London advised AmSafe Global Holdings on its all-cash $750m purchase by TransDigm Group Incorporated. The firm also recently succeeded, on behalf of Archstone-Smith Trust, in a significant arbitration concerning the alleged breach of tax-related covenants in tax-related agreements signed with investors in connection with a $1.6bn property contribution to Archstone. Practice clients include Brookfield Asset Management, Lazard, Macquarie and Providence Equity Partners.

White & Case LLP handles M&A, bankruptcy, securities and some capital markets and financial products work from its ‘timely and efficient’ New York, Washington DC and Miami offices. Recently busy with inbound cross-border work, it benefits from the international reach of more than 100 tax lawyers in 38 offices worldwide. New York is home to the firm’s greatest concentration of tax lawyers and headed up by global practice head William Dantzler. The firm recently advised Saudi Aramco on tax aspects related to its joint venture with The Dow Chemical Company to build and operate a $20bn integrated chemicals complex in Saudi Arabia, and represented Braskem on the issuance of $500m senior notes to private investors. Clients include sovereign wealth funds, multinational financial institutions, investment funds, tax-exempt organizations and corporations including Coca-Cola, Canada Housing Trust and BNP Paribas. John Lillis and Bruce Davis are recommended.

Thomas May heads up Baker & McKenzie’s international tax practice, which clients report is ‘much more efficient in managing projects than the Big 4 accounting firms’. The practice has seen a significant uptick in the amount of transactions it handles, including in relation to the tax aspects of public transactions, such as acting for ENSCO and Eagle Lab. The firm has also added strength in depth, including Mary Bennett, former head of tax treaty and financial planning at the OECD, Caroline Silberztein, former head of the OECD transfer pricing unit, and Joshua Odintz from the Treasury; the firm also recently formed a tax policy sub-group to advise clients on changes to tax laws. The main three subgroups are international tax planning and transactions, including M&A; transfer pricing; and controversy. Representative matters included acting for AXA Private Equity to structure and implement its $1.6bn acquisition of Bank of America’s secondary funds, and advising Sony Corporation of America and Mubadala Development Company during their bid and purchase of EMI’s music publishing business from Citigroup. Other practice clients include Abbott Laboratories, Skype Communications and Verisign. John McDonald is recommended of his ‘thorough, comprehensive, and timely analysis’.

Caplin & Drysdale’s boutique tax practice (‘first-rate service levels’) provides advice on inbound and outbound matters, having recently experienced a high-volume of work in the financial services sector with domestic and foreign insurance companies and major financial institutions. ‘Intelligent, efficient and timely’, Patricia Lewis leads the firm’s ‘excellent’ transfer pricing work for international clients including large Japanese, German and Swedish multinationals. David Rosenbloom advises multinational corporations and financial institutions in the US, Brazil, Australia and throughout Europe. Lucy Lee’s Korean practice continues to grow, advising Korean companies and high-net-worth individuals, including prominent athletes and entertainers on US tax issues. The firm maintains a major transfer pricing practice and has been instructed in significant treaty interpretation and transfer pricing matters, including inbound transfer pricing work from Canada, Japan, UK, and Australia. It is also currently advising on competent authority matters out of Canada, UK, India, Korea, Japan, Mexico and Australia.

Dechert LLP’s international tax practice group is composed of 23 lawyers in offices on both sides of the Atlantic, including Boston, Brussels, London, Munich, New York, Paris, Philadelphia and Washington DC. Within the international tax group, led by Daniel Dunn, individuals have particular expertise in automotive, financial services, gaming, retail and telecommunications industry sectors, among others. Dunn recently represented Connors Bros Holdings in a transaction which required intensive cross-border tax work concerning the $980m sale of certain of its operating subsidiaries, to funds advised by London-based private equity firm Lion Capital. Edward Lemanowicz represented Prodigy Health Holdings, a portfolio company of One Equity Partners, in connection with the sale of Prodigy Health Group, for $600m to Aetna Health Holdings, a subsidiary of Aetna. Practice clients include ING, UBS, Janus Capital Group and Goldman Sachs.

Gibson Dunn’s tax practice, based primarily in Washington DC, New York and Los Angeles, numbers some 30 lawyers, amongst which the international tax lawyers have attracted a strong following and represent large multinational corporations to entrepreneurs and start-up companies. The group advises domestic and international clients in both inbound and outbound international transactions. Arthur Pasternak, who heads up the department from Washington DC, is an expert in cross-border corporate and real estate work. David Rosenauer and Romina Weiss specialize in private equity transactions including and regularly handle complex cross-border matters. Practice clients include Heineken, CVC Venture, Credit Suisse Alternative Investments and Arcapita Bank.

Stephen Land leads Linklaters’ practice in New York, regularly advising on tax aspects of domestic and international M&A and corporate finance matters including public international debt and equity offering, corporate restructurings, structured financing arrangements and joint ventures. Recent highlights include advising Deutsche Borse on its merger with NYSE Euronext, and advising Glencore International on its IPO and listing on the London and Hong Kong Stock Exchanges. Clients include Citigroup, RBS, Barclays and Rio Tinto. Gordon Warnke joined the firm from Dewey & LeBeouf LLP.

With over 40 lawyers in its global tax practice and 30 in the US engaged in international tax in Silicon Valley, Washington DC, Chicago and New York, McDermott Will & Emery LLP provides a wide range of international inbound and outbound services to its clients including transactional support, tax planning, and international restructuring. Lowell Yoder, widely recognized as an expert in international and corporate tax planning, leads the practice from the firm’s Chicago office, which is currently advising McGraw-Hill on the tax aspects of the formation of a non-US holding company for its international operations and the tax efficient reorganization of these operations. Stephen Wells leads the Washington DC team, which serves the needs of major Fortune companies on the tax aspects of M&A and corporate restructurings, typically handling the US aspects of cross-border deals. Wells’ team is currently acting for Tyco International on the structure and tax implications of that company’s proposed multi-billion three-way separation in a tax-free spin-off transaction. Thomas Giegerich heads the New York practice, which is currently advising Sumitomo Corporation of America on the tax aspects of domestic and cross-border acquisitions and financing, as well as representation in tax controversy matter. The firm’s Silicon Valley office, headed by Fred Chilton advises high-tech clients on cross-border IP tax planning and structuring. Other clients include Credit Suisse, Diageo, Citigroup and Bayer.

New York-based Paul, Weiss, Rifkind, Wharton & Garrison LLP lawyers work closely with the London, Tokyo, Hong Kong and Beijing offices in the M&A and multinational restructuring space. Richard Bronstein and Jeff Samuels co-head the practice, which recently represented a UK-based private equity fund in its purchase of a Brazilian operating company, involving a $500m exit. Practice clients include KKR, Carlyle, Morgan Stanley and Capital International.

Practice head Stuart Schaffer and Derek Green lead Baker Botts L.L.P.’s international tax work from the firm’s Houston office with support locally and from New York. Highly regarded in the global energy sector, particularly in oil and gas, the firm advises foreign and domestic clients on inbound and outbound cross-border matters. It handles projects, M&A, restructurings and financings, including asset leasing. The firm’s tax planning work cuts across the full spectrum of business activities and it works with the world’s largest corporations and independent businesses. It recently represented Pride International in its $8.7bn merger with Ensco, the world’s second largest offshore drilling company, and provided US tax advice to Liberty Global in connection with its $2.7bn acquisition of 100% of the stock of AUSTAR United Communications. The firm has a strategic alliance with Ceteris, a transfer pricing and valuation advisory firm.

The strongest concentration of talent within the international tax practice at Bingham McCutchen LLP continues to be located in Washington DC with four dedicated partners. However, the firm has recently undergone significant expansion on the West Coast and the international tax practice at the firm’s office in Silicon Valley, which serves clients whose primary US presence is in Northern California, has been bolstered by the arrival of John Ryan from McDermott Will & Emery LLP. The firm advises on all aspects of inbound and outbound international taxation, including subpart F, foreign tax credits, treaty interpretation and the taxation of cross-border hybrid instruments. Clients include major US and foreign companies in the financial services, energy, entertainment and media, technology, pharmaceutical and healthcare industries. It recently represented taxpayers Salem Financial and Santander Holdings USA in separate foreign tax credit generator cases.

Covington & Burling LLP handles pure transactional work, tax consulting, and legislative work in roughly equal measure. Appeals and controversy work ties into the firm’s practice, the bulk of which is centered in Washington, except for M&A work which is handled from New York. Transfer pricing expert Bill Chip recently obtained the first-ever IRS pre-filing agreement to approve in advance a taxpayer’s method for demonstrating treaty eligibility. Rob Culbertson (‘excellent client service’) recently represented some of the largest US and non-US based multinationals in connection with their structural and transactional tax planning, including advice concerning cross-border acquisitions, restructuring, and financings. Partnership tax expert Dan Luchsinger was recently named co-chair of the tax group and is currently handling tax planning for three separate multiple hundredmillion-dollar royalty investments in international patent companies, involving complex US and non-US cross-border tax issues, including partnership, withholding and treaty interpretation issues. Dirk Suringa is developing and implementing the international restructuring of affiliated multinational sports licensing and media companies for a major US sports and media company in the US and Netherlands. The firm recently picked up new client Kommerzbank as well as having seen growth in the pharmaceutical and information sectors. It also represents banking clients including Barclays, Natixis and Brown Brothers Harriman on cross-border issues. Dirk Suringa is recommended for his ‘exceptional command of international tax issues’.

David Colker heads up DLA Piper LLP’s global international tax group (‘good at presenting issues and making practical recommendations’) from the firm’s Silicon Valley office, with partner-level representation in the US also in New York, which includes a European desk, Washington DC and Boston. The firm has particular expertise in corporate tax advisory services, outbound investments, transfer pricing, tax controversy, inbound investments, cross-border licensing, real estate tax services, private equity investment, and equity investment and incentives tax services. Gerald Rokoff, who has extensive experience in advising on international tax structuring, recently joined the New York tax practice from White & Case LLP.

Over 25 of Greenberg Traurig LLP lawyers spend the majority of their time working on international tax matters from the firm’s offices in Boston, New York, Miami, London, Amsterdam, Denver, Washington DC. The firm has recently been instructed in multi-billion IPOs, MA, and financings. It acts for major US and foreign investment banks and multinationals and is particularly recommended for its work in Latin America.

Kirkland & Ellis LLP’s practice has seen exponential overseas growth, opening offices in Shanghai and adding new partner Angela Russo’s tax expertise to its Hong Kong office. The firm recently advised new client Trononx and its affiliates through its Chapter 11 reorganization including in the development and confirmation of a consensual plan based on a heavily negotiated creditor settlement to resolve billions of dollars in liabilities with general unsecured creditors and equity holders also getting a stake in the reorganized business. The firm also represented Apax Partners, Madison Dearborn Partners and TA Associates in connection with the tax aspects of their $7bn sale of interest in Wind Telecom to VimpelCom. Other active clients include Bain Capital and iGate Corporation.

Mayer Brown’s transactional and tax planning practice, co-chaired by Kenneth Klein and James Barry, comprises more than 70 lawyers worldwide representing claims in a wide variety of matters including M&A, restructuring, planning and government relations. The firm’s tax controversy practice, jointly headed up by Joel Williamson and Larry Langdon, numbers some 40 lawyers worldwide, including offices in Europe and Latin America. The firm is advising a US client on international tax issues connected with a $1bn acquisition, as well as ongoing representation to Forest Laboratories. Representative clients include Altria Group, LBO France, The Jordan Company and The Carlyle Group (Europe).

Thomas Humphreys heads up Morrison & Foerster LLP’s nine-strong international tax team across the US in New York, San Francisco and San Diego that handles cross-border assignments in conjunction with colleagues in established Tokyo, Hong Kong, Shanghai and Beijing offices. Humphreys and Remmelt Reigersman represent RBC Capital Markets on all US tax aspects with respect to its structured notes offerings including equity, currency, ETF and commodity-linked products and recently represented that client in a novel matter with respect to the tax aspects of the creation of notes linked to the EquityCompass Equity Risk Management Strategy. Robert Cudd represented Clorox Company in a carve-out transaction in which it sold its interests in its domestic and foreign automobile care products for $800m to a private fund involving domestic and numerous foreign operations with royalty structures. Key clients include BNP Paribas, Bank of Montreal and Landisbanki.

Paul Hastings LLP’s global tax practice, which spans the firm’s 18 offices in the US, Europe and Asia, also reaches across all industries and types of businesses and across both established and emerging economies and markets. The firm’s transactional practice, which is well connected in the financial sector, covers M&A, capital market offerings, investment and joint venture structuring, leasing, structured and project finance, and financial product planning and structuring. It has particular expertise in telecommunications, real estate, executive compensation, and tax-exempt and tax-favored investments. Alexander Lee, who shares his time between Los Angeles and San Diego, is known for his work in Asian markets, and New York-based Andrew Short has a practice with a strong European flavour. Practice clients include Citigroup Global Markets Asia, Deutsche Bank, Paladin Capital and Threadneedle.

Jerome Libin leads Sutherland Asbill & Brennan LLP’s broad-based Washington DC tax practice, whose 11 partners handle international tax planning and transactional work for major multinationals. It recently advised Coca-Cola Enterprises on tax and employee benefits in connection with the split-off of its international bottling operations. The firm has also recently seen a high-volume of work advising on FACTA compliance issues and other withholding regimes. In the M&A space, it represented Tyco Electronics regarding the tax aspects of the $675m sale of its wireless systems business to Harris Corporation, and in separate matter advised on the extraction of underlying US businesses without triggering tax in connection with a major foreign acquisition. Practice clients include American International Group, Amazon, General Motors and Lincoln Financial. Amish Shah was promoted to the partnership.

The full service tax practice at Vinson & Elkins L.L.P. is best known for its Houston energy practice with expertise in oil, gas, and alternative energy. The firm works with international clients in Canada, across Asia (in particular China) and other energy centers, including Brazil. The firm recently has seen a high-volume of tax work in the M&A and IPO space as well as handling some significant joint ventures. Tom Crichton is known for his international pricing and transfer disputes as well as MLP work; George Gerachis serves as head of the tax and employment benefits/executive compensation department; and David Peck is sought after in complex private equity transactions. The firm represented CNOOC International as tax counsel in connection with the first significant investments ($3.47bn combined from Chesapeake Energy) in the US energy sector by a Chinese company, since the unsuccessful attempt by CNOOC to acquire Unocal in 2005. Active clients include Nobel Energy, Denham Capital Management, ESSO UK and Statoil.

Howard Rothman leads Kramer Levin Naftalis & Frankel LLP’s tax group, which has seen an uptick in international clients and acquisitions for domestic clients with foreign subsidiaries. The firm is well regarded for joint ventures and partnerships, individual international tax planning and its representation of entertainment and media industry clients. Highlights included representing First Investors Consolidated Corporation in connection with its acquisition by Canadian life insurance provider Foresters and a high-volume of negotiations with the IRS and other jurisdictions on behalf of entertainment related clients in connection with audits, central withholding agreements, offers in compromise and instalment agreements.

Chicago-based Sharp Sorensen leads Sidley Austin LLP’s international tax offering which builds on the firm’s solid domestic practice and handles cross-border transactions with a European element. Sorenson and Drew Scott from London recently supported the firm’s corporate department advising Western Union on the tax aspects of its $976m acquisition of the global business payments division of UK-based Travelex Holdings. Laura Barzilai provided tax advice to Bermuda-based reinsurer Validus Holdings in the formation of a newly formed special purpose sidecar reinsurer.

Simpson Thacher & Bartlett LLP’s unified international tax practice comprises eight well-leveraged partners across its New York, Paolo Alto and London offices, centered around transactional M&A, acquisitions and dispositions, REITs and private equity fund work – a particular strength, with clients including KKR, Blackstone and Silver Lake. The firm also has an established capital markets practice, representing major investment banks including JPMorgan. Steven Todrys recently represented The Mosaic Company in its split-off from Cargill, and the Sealed Air Corporation in its $4.3bn acquisition of Diversey Holdings. Robert Holo advised Japan’s Toshiba Mercantil Colpatria in its acquisition of a 49.77% stake owned by General Electric Capital Corporation in Banco Colpatria Multibanca Colpatria, and PPL Corporation and its UK subsidiaries in their £4bn acquisition of Central Networks’ electricity distribution business form E.ON UK.

Steptoe & Johnson LLP’s Washington DC-based international tax practice, chaired by Philip West (‘superb technical expertise’), comprises five partners specialising in international tax and another 36 tax partners practice-wide. West led the firm’s advice to the Government Development Bank for Puerto Rico and other Puerto Rico government agencies with respect to the enactment of a new excise tax imposed on related party transactions involving Puerto Rican manufactured goods, and certain modifications to the Puerto Rico income tax rules regarding the taxation of non-resident companies, expected to increase revenues by $6bn over six years. The firm also assisted TD Bank with a number of tax legislative and transactional tax projects including legislative and administrative advocacy in connection with tax policy reform, the proposed “bank tax” and the FACTA. Alexis MacIvor was elevated to of counsel in January 2011.