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International tax in United States

Baker McKenzie LLP

Baker McKenzie LLP has an expansive bench of international tax experts advising on multi-jurisdictional tax optimization and post-acquisition structuring for long-term, global corporate clients. Complex partnership agreements and transactions are handled by Washington DC-based co-chair Rafic Barrage, who is highly active in the life sciences, manufacturing and shipping sectors, and Palo Alto-based Stewart Lipeles, who recently handled high-value projects in the technology and financial services sectors. Melinda Phelan in Dallas and Jeff Maydew in Chicago are also in leadership positions in the team. Other names to note include Palo Alto-based digital tax expert Gary Sprague and Houston-based supply chain and IP planning expert Jonathan Martin. The team’s highly integrated advisory and strategic approach is considered by peers to be a viable Big Four contender for comprehensive international tax advice.

Practice head(s):

Melinda Phelan; Jeff Maydew; Rafic Barrage

Other key lawyers:

Stewart Lipeles; Gary Sprague; Jonathan Martin

Testimonials

‘The team is widely connected and has a very comprehensive understanding of global developments which may impact their client. I believe they are especially good at melding this insight with high technical expertise to deliver best-in-class services to their clients.’

‘They are very adept at speaking with their clients in an understandable, respectful and collaborative manner.’

Key clients

Nuance Communications, Inc.

Trimble Navigation Limited

Work highlights

  • Advising Trimble on various international tax planning matters, including acquisitions, transfer pricing and restructuring following significant foreign acquisitions.
  • Advised Nuance Communications on global tax planning and restructuring matters.

Kirkland & Ellis LLP

Kirkland & Ellis LLP’s international tax practice maintains a reputation as a go-to team for high-end transactions in the corporate and private equity fields. An integral part of what is a top-tier firm in the restructuring space, the team is well placed to handle the recent uptick in distressed M&A, insolvencies and workouts; in this regard, practice co-heads Todd Maynes and Dean Shulman (based in Chicago and New York, respectively) advised on a number of headline bankruptcies in the aviation, retail, travel, leisure and energy sectors. The group is also active in the burgeoning SPAC space, where Lee Morlock, Rachel Cantor and Mike Carew in Chicago, and Jared Rusman, Sara Zablotney and David Grenker in New York are names to note. New York-based Mike Beinus handles complex partnership transactions and REIT structuring. Multibillion-dollar, tax-driven investment fund formation is another strength for the team. Richard Husseini was a new arrival in the firm's Houston office at the end of August in 2021. Mark Schwed was a new arrival in April 2021.

Practice head(s):

Todd Maynes; Dean Shulman

Other key lawyers:

Lee Morlock; Rachel Cantor; Mike Carew; Jared Rusman; Sara Zablotney; David Grenker; Mike Beinus; Richard Husseini; Mark Schwed

Key clients

Abbvie Inc.

Ares Management Corporation

Bain Capital Private Equity

Bristol-Myers Squibb

Danaher Corporation

Grubhub

Huntsman Corporation

United Airlines Holdings

Vista Equity Partners

Warburg Pincus

Work highlights

  • Advised the bidding consortium led by Advent, Cinven and the RAG-Stiftung (RAG foundation) on the tax aspects of its $18.7bn acquisition of the elevator division of Thyssenkrupp AG.
  • Advising Grubhub, a leading online and mobile food ordering and delivery marketplace, on the tax aspects of its agreement to be acquired by Just Eat Takeaway.com N.V. in an all-stock deal for a total equity consideration of $7.3bn.
  • Advised Neiman Marcus Group and 23 of its affiliates on the tax aspects of its Chapter 11 filing.

Mayer Brown

Mayer Brown’s international tax experts handle a solid mix of inbound and outbound transactions, including M&A, structured finance, real estate finance and capital markets transactions involving the EMEA, Asia-Pacific and Latin America regions. Key partners include co-chair Jason Bazar in New York, Washington DC-based shipping tax expert Kenneth Klein, and Jason Osborn (also in DC), who has exceptional knowledge of multilateral advanced pricing agreement (APA) negotiations. Noted fields of expertise include transfer pricing issues and cross-border integrations, handled by New York-based Lucas Giardelli, Chicago-based co-chair James Barry and Michael Lebovitz in Los Angeles. The team works in a holistic manner with the tax controversy group for early-stage risk mitigation assessments. Global corporates, financial institutions, asset managers and investment funds are among the team's core clients.

Practice head(s):

James Barry; Jason Bazar

Other key lawyers:

Kenneth Klein; Jason Osborn; Lucas Giardelli; Michael Lebovitz

Key clients

Altice N.V. & Altice USA Inc.

Nestlé SA

The Dow Chemical Company

Sotheby’s Inc.

Eaton Corporation

Abbott

Goldman Sachs

World Shipping Council

Prudential

Work highlights

  • Advised Goldman Sachs Lending Partners on a first-of-its-kind $6.8bn financing of United Airlines, secured by United Airlines’ loyalty program, MileagePlus.
  • Represented BidFair USA, an entity wholly owned by media and telecom entrepreneur and art collector Patrick Drahi, in the $3.7bn acquisition of Sotheby’s, the fine art, collectibles and jewelry auction house.
  • Represented Nestlé Health Science in its $2.6bn acquisition of Aimmune Therapeutics, a biopharmaceutical company developing and commercializing treatments for potentially life-threatening food allergies.

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP’s corporate tax partners assist major US and multinational corporates with cross-border transactions including M&A, spin-offs, partnership agreements, joint ventures and energy project finance transactions. Global tax group head Eric Sensenbrenner, Hal HicksSteven Matays, David Rievman and Gavin White lead the way on headline deals in the media and entertainment, telecoms, technology, healthcare and investment management sectors. The practice group is based in the New York office.

Practice head(s):

Eric Sensenbrenner

Other key lawyers:

Hal Hicks; Steven Matays; David Rievman; Gavin White

Cleary Gottlieb Steen & Hamilton

Cleary Gottlieb Steen & Hamilton’s tax practice leads on headline, multi-jurisdictional transactions for a diverse client roster. Practice co-head Jason Factor advises top-flight foreign private equity and hedge funds on portfolio acquisitions and PIPE transactions, while William McRae advises premier international sovereign wealth funds—including real estate investment platforms and state-owned pension plans—on the tax structuring of multibillion-dollar inbound deals and ongoing operations. Meyer Fedida and Corey Goodman regularly assist with M&A in areas including financial services, media and entertainment, aerospace, oil and gas and life sciences. Joint practice head Diana Wollman is an expert in international tax structuring, having previously worked as director of international strategy at the IRS; she is also a key name for audits and investigations, and has particularly deep knowledge of the base erosion and anti-abuse tax (BEAT) directive. Named lawyers are based in New York.

Practice head(s):

Jason Factor; Diana Wollman

Other key lawyers:

William McRae; Meyer Fedida; Corey Goodman

Key clients

BNP Paribas

International Flavors & Fragrances

LATAM Airlines Group S.A.

Alphabet/Google

National Amusements, Inc.

Warburg Pincus

ESL Investments

3M

Agilent Technologies

LVMH

American Tower

Work highlights

  • Represented International Flavors & Fragrances in its $45.4bn merger with DuPont Nutrition & Biosciences in a Reverse Morris Trust transaction.
  • Represented National Amusements in its $30.5bn merger of CBS and Viacom.
  • Represented Google in its $2.1bn acquisition of Fitbit.

Cravath, Swaine & Moore LLP

A top-flight firm for corporate transactions, Cravath, Swaine & Moore LLP fields a robust tax team which is regularly engaged in headline multi-jurisdictional mandates. Highlights over the review period have included a high volume of distressed workouts (including for UK-based companies) and SPAC-driven deals. In the latter area, Lauren Angelilli handled numerous transactions in the healthcare space. The group is also routinely involved in high-value M&A, recent examples of which have seen co-head Stephen Gordon and Leonard Teti advising on multibillion-dollar, cross-border deals in the telecoms, pharmaceuticals, energy and automotive sectors. Andrew Needham and Christopher Fargo are key partners for REITs, and Kara Mungovan brings an impressive body of knowledge regarding global intangible low-taxed income (GILTI) fees. All named attorneys are based in New York.

Practice head(s):

Stephen Gordon; Lauren Angelilli

Other key lawyers:

Leonard Teti; Andrew Needham; Christopher Fargo; Kara Mungovan; Michael Schler

Testimonials

‘The Cravath tax practice is highly technically competent, you can trust their advice. They are judicious in their approach and efficient in their time spent on issues. They communicate well both in conversation with the client, their technical advice and in coordination with other parties in a transaction. They demonstrate high professional standards in terms of proficiency and professionalism.’

‘Michael Schler has been a long-time adviser and trusted counselor. His technical knowledge, analytical ability, judgement, communication effectiveness, interest and knowledge of our business and general reliability are beyond any external tax adviser used by our company. Mike stands out amongst his peers and is a well-regarded leader in the corporate tax profession.

‘Andrew Needham is an excellent partner and trusted advisor and counselor, exceptionally easy to work with, technically proficient, knowledgeable and pragmatic.’

Key clients

Avon

Bharti

Centrica

Deutsche Börse

Deutsche Telekom

Disney

Just Eat Takeaway.com

Mylan

Peugeot

Prosus

Unilever

Work highlights

  • Provided tax advice to Mylan on its $50bn combination with Upjohn, Pfizer’s off-patent branded and generic established medicines business, as part of a Reverse Morris Trust transaction, creating a new global pharmaceutical company, Viatris.
  • Providing tax advice to The Unilever Group on the unification of its dual‑headed structure under a single parent company, Unilever plc, resulting in a streamlined company with a market capitalization of over $150bn, based on current market values.
  • Providing tax advice to Peugeot on its pending $50bn merger with Fiat Chrysler Automobiles N.V.

Davis Polk & Wardwell LLP

Davis Polk & Wardwell LLP’s international tax practice is an integral component of the firm’s market-leading corporate transactions service. Jointly led by Neil Barr and David Schnabel, the team is especially active in high-value M&A, but is also routinely involved in capital markets and derivatives deals, fund formation and corporate restructuring. Another key figure in the team is Po Sit, a fluent Mandarin and Cantonese speaker, who leads the tax advice for many of the firm's inbound mandates from China. Elsewhere, the team has extensive experience in real estate, having represented premier clients including Morgan Stanley in the formation of public and private REITs. Also recommended is William Curran, who recently advised dominant Indian conglomerate Reliance Industries and its subsidiaries on high-value partnership agreements and inward investments. The practice group is based in New York.

Practice head(s):

Neil Barr; David Schnabel

Other key lawyers:

Po Sit; William Curran

Key clients

ABB

Advanced Accelerator Applications

Aetna

The Brink’s Company

Bristol-Myers Squibb

Comcast

Emerson Electric

ExxonMobil

Federal Express Corporation

The Ferrero Group

Fortress Investment Group

GE

HRG Group Inc.

KKR

L Brands, Inc.

Lockheed Martin

McKesson Corporation

NBCUniversal Media, LLC

Novo Nordisk

Reckitt Benckiser

Reynolds

Roche

SS&C SUEZ

Tyson Foods

Williams Partners

Credit Suisse

Goldman Sachs

J.P. Morgan

Morgan Stanley

Debevoise & Plimpton LLP

The international tax experts at Debevoise & Plimpton LLP work hand-in-hand with the firm’s top-tier corporate transactions group to deliver comprehensive tax advice on headline deals. Co-head Peter Schuur is highly sought after in the insurance sector, where clients including Prudential, MetLife and AXA frequently approach him for advice on top-flight M&A deals, disposals, multibillion-dollar reinsurance exchanges, distribution agreements and all other corporate activity. Co-head Peter Furci and Rafael Kariyev have a focus on private equity and investment funds, covering emerging market funds, hedge funds and REITs. Also recommended in the team are Gary Friedman, Michael Bolotin, Erin Cleary and newly promoted partner Daniel Priest, all of whom are noted for their robust international tax and regulatory knowledge in the context of headline corporate transactions. The team is based in New York.

Practice head(s):

Peter Schuur; Peter Furci

Other key lawyers:

Rafael Kariyev; Gary Friedman; Michael Bolotin; Erin Cleary; Daniel Priest

Testimonials

‘Having Debevoise & Plimpton on board enables us to seamlessly and consistently handle our projects. The team aligns with other offices within the firm where there is a cross-border or international element. The team has high professionalism, responsibility, customer focus, rapid response.’

Key clients

Artera Services, LLC

AVEVA Group

Blackstone

BrandSafway

Clayton, Dubilier & Rice

Global Atlantic Financial Group

Interxion

Johnson & Johnson

Lightspeed

The Special Committee of the Board of Directors of Match Group Inc.

Morgan Stanley

New York Life Insurance

Pathway Vet Alliance

Prudential

Resolution Life

Third Point Reinsurance Ltd.

Verizon

Warner Music Group

Work highlights

  • Advising AVEVA Group, a global leader in industrial software, on its $5bn acquisition of OSIsoft.
  • Advising Third Point Reinsurance on its merger with Sirius International Insurance Group in a transaction valued at $788m.
  • Advising Prudential and Jackson National on the reinsurance to Athene of $27.6bn of Jackson’s in-force book of fixed and fixed index annuities in exchange for an approximately $1.25bn ceding commission and a $500m equity investment in Jackson’s holding company.

Dechert LLP

Dechert LLP is a top choice for financial services institutions, assets managers and large-scale funds seeking advice on international tax planning. In New York, practice head Joshua Milgrim, Daniel Dunn and Steven Clemens advise private equity and sovereign wealth funds on tax planning issues relating to investments, holding company structuring, M&A and buyouts. Washington DC-based William Cejudo and Michael Rufkahr act for global asset managers on structured finance transactions, including distressed asset funds, mortgage securitizations and ABS. The team also has experience of REITs and offshore fund taxation. New York-based Ari Zak is a leader in the mutual funds space, as well as closed-end funds, exchange-traded funds and other complex fund products. Adrienne Baker in Boston also has expertise in fund formation mandates.

Practice head(s):

Joshua Milgrim

Other key lawyers:

Daniel Dunn; Steven Clemens; William Cejudo; Michael Rufkahr; Ari Zak; Adrienne Baker

Key clients

B&G Foods

Barings

Court Square Capital Partners

CVC

Fannie Mae

FS/KKR Advisor

GIC

LF Capital

One Equity Partners

Quest Diagnostics

Quilvest

Work highlights

  • Representing GIC, the sovereign wealth fund established by the Government of Singapore, in connection with the sale of Refinitiv to the London Stock Exchange Group for an enterprise value of $27bn in an all-stock transaction.
  • Advising FS/KKR Advisor (the external adviser to FS KKR Capital Corp. and FS KKR Capital Corp. II) and each of FSK and FSKR in connection with the merger of FSK and FSKR.
  • Advised CVC Credit Partners, the dedicated credit arm of private equity firm CVC Capital Partners, on successfully raising $657m for its second US focused direct lending fund, CVC Credit Partners US Direct Lending Fund II.

DLA Piper LLP (US)

The highly diverse international tax practice at DLA Piper LLP (US) handles complex, standalone tax planning mandates for a global client base. On the West Coast, co-chairs Sang Kim and Sibel Owji (based in Silicone Valley and San Francisco, respectively) are retained by world-leading names in the technology and life sciences sectors, with stand-out work including India- and China-based inbound joint ventures, transfer pricing strategy, APAs and worthless stock reductions. Further key partners include Philip Rogers, Kevin Glenn and Frank Mugabi in New York, Michael Hardgrove in Boston, and Ben Olivas in Silicone Valley. Additional team strengths include BEAT mitigation strategy, supply chain conversions and and tax-efficient migrations. Also of note, the firm has touted its commitment to diversity, with over 70% of recent promotions being female or ethnic minority lawyers.

Practice head(s):

Sang Kim; Sibel Owji

Other key lawyers:

Philip Rogers; Kevin Glenn; Frank Mugabi; Michael Hardgrove; Ben Olivas; Maruti Narayan; David Cook

Testimonials

‘I have direct access to the partners who have significant expertise. They know exactly who to bring in to round out the team on complex matters. They are also very quick to respond with complete and practical solutions.’

‘Philip Rogers – amazing relationship and lead partner. Not only does he understand the technical topics, but his high level of business acumen helps him easily navigate and understand the complexities of our business.’

‘Maruti Narayan is one of the best technicians I have worked with in 20+ years. Practical, technical and personable. Her ability to diffuse tense situations and recognize all opinions at the table while maintaining control of the discussion is admirable.’

‘David Cook has wide experience across outbound international tax, transfer pricing, customs matters and foreign tax issues that is indispensable.’

Key clients

International Flavors & Fragrances

Insmed, Inc.

Tonix Pharmaceuticals

MKS Instruments, Inc.

Cold Chain Technologies

Klockner Pentaplast Group

Work highlights

  • Advised and implemented post-acquisition integration plans for International Flavors & Fragrances, which included, but were not limited to (1) integrating certain local country operations and manufacturing operations to reduce redundancies, and (2) tax planning related to the combined operational structure and associated inter-company arrangements drafting and execution.
  • Acting for MKS Instruments in the structuring and post-acquisition integration of Newport Corporation and Electro Scientific Industries, via design and implementation of post-acquisition integration planning related to its entity structure, operating model, and IP structure.
  • Engaged by Klockner Pentaplast Group to restructure various entities within the group in order to more effectively and efficiently manage its business.

Eversheds Sutherland

Standout names in Eversheds Sutherland's international tax practice include Washington DC-based partners Robert Chase, Aaron Payne and Caroline Setliffe, all of whom provide strategic advice on outbound and inbound tax planning and also provide assistance with M&A and reorganizations. Further, the team advises cross-border funds on establishing international structures for US investment and also stands out in debt repurchasing transactions. New York-based Bruce Wright has extensive experience in matters at the intersection of tax and insurance law, and is particularly sought after in the captive insurance industry. Washington DC-based Mary Monahan has a strong breadth of knowledge of payroll, permanent establishment and income tax issues, particularly for big-tech companies. Washington DC-based Jeffrey Friedman heads the practice group.

Practice head(s):

Jeffrey Friedman

Other key lawyers:

Robert Chase; Aaron Payne; Caroline Setliffe; Bruce Wright; Mary Monahan

Key clients

Vitol

Chemoil Corporation

Kahn

Horowitz

Deutsche Börse

Columbia Care

Work highlights

  • Representing an international energy trading company in its development of a carbon capture and sequestration facility that is expected to generate significant tax credits under the revised section 45Q carbon capture and sequestration credit.
  • Represented Deutsche Börse in its acquisition of a majority interest in Quantitative Brokers LLC.

Fenwick & West LLP

The team at Fenwick & West LLP handles international tax planning for a variety of corporate entities, including Fortune 500 companies. Contacts in the Mountain View office include Larissa Neumann and James Fuller.

Latham & Watkins LLP

Latham & Watkins LLP provides comprehensive tax advice on market-leading international transactions, including REITs deals, the formation of master limited partnerships, cross-border M&A, securitizations, IPOs and investment fund formation. Of note in the past year, and reflective of the firm's strength in the private equity space, the team handled a spate of significant acquisitions was handled for The Carlyle Group. Key figures in the New York office include global tax chair Jiyeon Lee-LimLisa Watts and Elena Romanova, while Chicago-based practice co-head Joseph Krosnoble leads the charge on impressive Chapter 11 restructuring mandates, recently for financial services, manufacturing and pharmaceuticals debtors. Also recommended is Tim Fenn in Houston, who is well placed to handle mandates in the oil and gas sector, including restructuring and joint partnership agreements.

Practice head(s):

Jiyeon Lee-Lim; Joseph Krosnoble

Other key lawyers:

Lisa Watts; Elena Romanova; Tim Fenn

McDermott Will & Emery LLP

The tax team at McDermott Will & Emery LLP is sought out by prestigious global corporates, including Fortune 100 companies, for strategic advice on international tax planning and cross-border operations. Spearheaded by Washington DC-based Timothy Shuman, and featuring partners Lowell Yoder and Damon Lyons in Chicago, Michael Silva in Miami and Caroline Ngo in Washington DC, the team is adept at handling the tax aspects of M&A, spin-offs, and corporate restructuring, and is also noted for its expertise in transfer pricing matters. In addition to its strong corporate client base, Arianne Plasencia (who recently joined from DLA Piper LLP (US)) represents high-net-worth individuals in estate planning, inbound investment planning and cross-border disputes. Britt Haxton in Washington DC and Brian Jenn in Chicago are rated for their knowledge of domestic and international regulatory issues, and have experience of issues relating to foreign tax credits and bilateral tax treaties.

Practice head(s):

Tim Shuman

Other key lawyers:

Damon Lyons; Michael Silva; Caroline Ngo; Britt Haxton; Brian Jenn

Key clients

Coty

Aon

Procter & Gamble

sticky.io

Bank of America Merrill Lynch

Work highlights

  • Representing Aon in its $30bn acquisition of Willis Towers Watson in an all-stock transaction deal that would make it the world’s biggest insurance broker.
  • Advised Coty (as US tax counsel) on its strategic transaction with KKR with a deal value of approximately $4bn.
  • Providing restructuring advice – both on an ad-hoc/ongoing basis, and with respect to specific transactions – to Procter & Gamble.

Paul, Weiss, Rifkind, Wharton & Garrison LLP

New York-based Paul, Weiss, Rifkind, Wharton & Garrison LLP leverages its strong relationships with top-flight investment banks to regularly secure impressive transactions across a range of international jurisdictions. Co-chairs Brad Okun, Scott Sontag and Jeffrey Samuels, alongside key partners Brian Grieve and Robert Holo, provide tax structuring advice on headline M&A for global private equity funds and conglomerates. Among its recent highlights, the team handled a spate of impressive mandates for clients including General Electric, Ingersoll-Rand and IBM, the last of which Sontag advised on a groundbreaking $34bn combination with Red Hat. Lindsay Parks added to recent successes in the private equity-backed space, having handled multibillion-dollar acquisitions of China-based digital companies. David Mayo is recommended for structuring advice on corporate partnerships and tax-free mergers.

Practice head(s):

Brad Okun; Scott Sontag; Jeffrey Samuel

Other key lawyers:

Brian Grieve; Robert Holo; Lindsay Parks; David Mayo

Key clients

Rocket Companies

Oak Hill Advisors

Teladoc Health, Inc.

KPS Capital Partners

General Electric

Roark Capital Group

Elanco Animal Health Incorporated

Värde Partners

Ingersoll-Rand plc

EagleTree Capital

L3Harris Technologies

Centerbridge

Nuance Communications

Foresight Energy LP

IBM

Diamond Offshore

Apollo Global Management

Pioneer Energy Services Corp

General Atlantic

3G Capital

Work highlights

  • Advised Elanco Animal Health Incorporated on its $7.6bn cash-and-stock acquisition of the animal health business of Bayer AG.
  • Represented General Electric in a number of noteworthy matters, including the sale of PK AirFinance, a Luxembourg-based aircraft business to Apollo Global Management, LLC and Athene Holding Ltd.
  • Represented Ireland-based global manufacturing company Ingersoll-Rand in the spin-off of its industrial unit to shareholders and the simultaneous merger of the business with Wisconsin-based Gardner Denver Holdings via a tax-free Reverse Morris Trust structure.

Shearman & Sterling LLP

Shearman & Sterling LLP’s international tax practice is headed up by New York-based Michael Shulman and Larry Crouch, who divides time between New York and Menlo Park. Shulman represents an impressive roster of regulated financial services companies and investment funds (both onshore and offshore) in complex tax structuring matters, while Crouch is a name to note for in-bound mandates from China, including the investment activity of sovereign wealth funds. The team also acts for sovereign funds from the Middle East and Canada. Kristen Garry and Jay Singer focus on cross-border M&A deals and spin-offs, while also providing tax-forward advice on big-ticket corporate restructurings. Of counsel Kevin Dolan is also recommended. Named lawyers are based in Washington DC unless stated otherwise.

Practice head(s):

Michael Shulman; Larry Crouch

Other key lawyers:

Kristen Garry; Jay Singer; Kevin Dolan

Key clients

Raytheon Company

ViacomCBS f/k/a Viacom Inc.

Celanese Corporation

Intercontinental Exchange

Tetra Laval International S.A.

Ecopetrol, S.A.

Canada Pension Plan Investment Board (CPPIB)

Banco Bradesco S.A.

GenMab

Ardagh

Anglo American

Work highlights

  • Advised Raytheon on its tax-free merger-of-equals transaction with United Technologies Corporation, which created Raytheon Technologies Corporation, the world’s most advanced aerospace and defense systems provider.
  • Advised Viacom on its merger with CBS Corporation.
  • Advising Celanese on its definitive agreement to sell its 45% equity interest in the Polyplastics joint venture to Daicel Corporation for $1.5bn.

Simpson Thacher & Bartlett LLP

Premier New York firm Simpson Thacher & Bartlett LLP fields a full-service international tax group, which is jointly led by newly elected practice head Nancy Mehlman, recent lateral hire Russel Light (from Kirkland & Ellis LLP), and newly promoted partner Sophie Staples. Leveraging a strong firm-wide private equity focus, the team regularly provides tax structuring advice on cross-border buyouts, M&A deals and minority investments for leading international funds. Involvement in headline IPOs for multinational technology conglomerates is reflective of the team’s capital markets expertise. The team draws its clients from Europe, Latin America and Asia, and is also routinely engaged in complex Canadian REIT transactions. Jonathan Goldstein is a go-to name for multibillion-dollar fund formations.

Practice head(s):

Nancy Mehlman

Other key lawyers:

Russel Light; Sophie Staples; Jonathan Goldstein

Key clients

Alibaba Group

Apax Partners

The Blackstone Group L.P.

The Carlyle Group

Centerbridge Partners

Digital Colony

EQT

GFL Environmental

Hellman & Friedman

Hilton Worldwide

Ingersoll Rand

Johnson Controls

J.P. Morgan

Kohlberg Kravis Roberts & Co., L.P.

Lightyear Capital

Microsoft Corporation

Patria Investments

Rockpoint Group

Silver Lake

SoftBank

The Toronto-Dominion Bank

Versum Materials

ZoomInfo Technologies

Work highlights

  • Advising Laborie Medical Technologies on its $680m strategic partnership with Urotronic.
  • Advising Waste Management on its acquisition of Advanced Disposal and the sale of $835m in assets to GFL Environmental.
  • Advised Silver Lake Partners on the establishment of a new long-term investment strategy including a $2bn minority investment by Mubadala Investment Company.

Sullivan & Cromwell LLP

Sullivan & Cromwell LLP has a strong reputation in cross-border corporate and financing transactions. Contacts in this space include Ronald Creamer and Davis Wang, both of whom are based in the New York office.

Weil, Gotshal & Manges LLP

Recent workflows for Weil, Gotshal & Manges LLP’s international tax practice have included tax-forward, global corporate restructurings in the oil and gas sector; exits in the for-profit healthcare space; and inbound investment structuring for prominent sovereign wealth funds. Kimberly Blanchard is a name to note for institutional investor work, having advised public pension funds on a suite of investments and recapitalizations. Greg Featherman acted on corporate and private equity-backed M&A and take-private transactions in the fintech sector. The team is also retained by a considerable number of SPACs, for which Devon Bodoh and practice head Joseph Pari handle big-ticket IPOs and forward purchase agreements. Mark Schwed left the firm in April 2021.

Practice head(s):

Joseph Pari

Other key lawyers:

Kimberly Blanchard; Greg Featherman; Devon Bodoh

Testimonials

‘A very smart and creative tax group.’

Key clients

Hour Fitness Worldwide, Inc.

Front Yard Residential Corporation

AK Steel Corporation

Genstar Capital, LLC

American Securities LLC

The Gores Group / Gores Metropoulos, Inc.

Apergy Corporation (n/k/a ChampionX Corporation)

Legg Mason

Berkshire Partners

Maxim Integrated Products, Inc.

Black Knight, Inc.

MGM Resorts

The Blackstone Group L.P.

Ontario Teachers’ Pension Plan

Brookfield Asset Management Inc.

PG&E

Brooks Brothers

PSP Investments

Campbell Soup Company

Legg Mason, Inc. YCEC Entertainment, Inc.

Sanofi S.A. N

Churchill Capital Corp III

SoftBank Group Corp.

CPP Investments N 29 SiriusXM

Dunn and Bradstreet Holdings, Inc.

Total S.A. N

Foley Trasimene Acquisition

TPG Capital/TPG Global

Froneri International Limited

Willis Towers Watson PLC

Work highlights

  • Advising Willis Towers Watson (Ireland), a global provider of corporate risk advisory services, on the tax aspects of its pending $80bn combination with Aon (Ireland), a provider of risk management, insurance placement and human resource, retirement and health consultation services.
  • Advising Churchill Capital Corp III, a SPAC sponsored by Churchill Capital group, on the tax aspects of its $5.7bn merger with MultiPlan (a portfolio company of Hellman & Friedman), a provider of healthcare cost-management solutions.
  • Advising Maxim Integrated Products—a designer, developer and manufacturer of integrated circuits—on the tax aspects of its $21bn sale to Analog Devices, a designer, manufacturer, and marketer of integrated circuits used in analog and digital signal processing, in a transaction that values the combined enterprise at over $68bn.

White & Case LLP

Led by global tax head Kim Marie Boylan in Washington DC and US tax head Sang Ji in New York, White & Case LLP handles international tax matters as a central component of the firm’s impressive cross-border corporate service. The team frequently handles strategic tax planning in connection to high-value M&A across an impressive range of jurisdictions, spanning the UK, Europe, Russia, the Middle East, Latin America and Australia. In addition to his expertise in investment and REIT fund formation, New York-based Andrew Kreisberg recently had a hand in Saudia Aramco’s landmark IPO on he Saudi Stock Exchange. Brian Gleicher heads up the dedicated transfer pricing practice from the Washington DC office, where he advises on international tax controversies and tax treaty resolutions.

Practice head(s):

Kim Marie Boylan; Sang Ji

Other key lawyers:

Andrew Kriesberg; Brian Gleicher

Testimonials

‘Technically strong, practical and responsive.’

‘Capacity of providing concise and actionable advice out of a highly complex topic. The memos provided by the company were outstanding when compared with other tax advisors.’

‘Quality of the work, thoroughness and quick response times.’

‘Very responsive, knowledgeable and practical team. And great people. Top notch. ’

‘Andrew Kreisberg is practical and has a deep understanding of our tax considerations. He is also a very nice guy.’

‘I am a transfer pricing economist and am speaking from my experience in working with White & Case on transfer pricing matters. The team that I have worked with (Kim Boylan and Brian Gleicher) are technically very competent, have been very responsive, and are easy to work with. They are both open to the ideas that I advance and are effective in providing constructive criticism when appropriate.’

Key clients

Saudi Arabian Oil Company (Saudi Aramco)

Brookfield Infrastructure

Roivant Sciences Ltd.

SoftBank Vision Fund

Lantheus Holdings, Inc.

Sony Corporation of America

College Pension Plan of British Columbia

EchoStar Corporation

MOL Hungarian Oil and Gas PLC

OpenText Corporation

Macquarie Infrastructure Partners

Sole Luna Pty Ltd.

Avon Rubber p.l.c.

Sociétée Générale

LANXESS

MERA International

Erste Group Bank AG

Work highlights

  • Represented Saudi Aramco in connection with its $29.4bn IPO on the Saudi Stock Exchange (Tadawul), the world’s largest IPO.
  • Represented Brookfield Infrastructure, which partnered with GIC Special Investments (Singapore’s sovereign wealth fund) in its $8.4bn acquisition of Genesee & Wyoming, a freight railroad owner and operator based in the US.
  • Represented Roivant Sciences, a global biotech company, in numerous M&A and capital markets transactions, including its most recent $3bn acquisition of Sumitomo Dainippon Pharma, a Japanese biopharma company.

Allen & Overy LLP

Based in New York, the team at Allen & Overy LLP provides comprehensive international tax advice and is led by Jack Heinberg, Dave Lewis and of counsel Caroline Lapidus. Transactional expertise spans cross-border M&A, financing agreements, inbound and outbound investments, IPOs and securitizations. Real estate transactions are another point of strength, with REITs, joint ventures and mezzanine financings featuring among the team's recent highlights. Lapidus recently worked with the firm's project finance group to advise a lending syndicate as financiers on a suite of international renewable energy projects. The team also advises fund mangers on a range of fund structuring matters for regulated, hedge and infrastructure funds.

Practice head(s):

Jack Heinberg; Dave Lewis; Caroline Lapidus

Testimonials

‘The international breadth of the firm makes it ideal for international deals.’

‘Jack Heinberg is an excellent tax practitioner- knowledgeable, responsive and practical.’

Key clients

Apax Partners

Goldman Sachs

WillScot Corporation

Network International Holdings plc

Bancomex

BBVA

Credit Agricole Corporate and Investment Bank (CACIB)

Natixis

Proparck

EKF

Societe Generale

Archer Daniels Project Web

JP Morgan

Citibank

TDR Capital

Work highlights

  • Advised Apax Partners and its portfolio company Neuraxpharm Group on the acquisition of the assets and rights related to prescription brand Buccolam from Takeda Pharmaceutical Company in a multinational asset deal.
  • Advised WillScot Corporation on its merger agreement with portable storage solutions provider Mobile Mini; the public company combination creates an industry-leading specialty leasing company with a total enterprise value of $6.6bn.
  • Representing six lenders (Bancomex, BBVA, Credit Agricole Corporate and Investment Bank, Natixis, Propark and EKF) as guarantor financiers on a portfolio of renewable energy projects developed, financed, constructed, owned, operated and maintained by a joint venture between ENGIE and Tokyo Gas.

Baker Botts L.L.P.

Baker Botts L.L.P.’s international tax practice advises on cross-border tax planning in the context of M&A, equity investments, joint ventures and project financings. The team has also acted as tax counsel in large bankruptcy proceedings. Contacts in the Houston office include Jon Lobb, Ron Scharnberg and Derek Green, the last of whom has been handling multibillion-dollar restructurings in the oil and gas sector. Since publication Richard Husseini has left the firm.

Other key lawyers:

Derek Green; Jon Lobb; Ron Scharnberg

Testimonials

‘Smart and proactive.’

‘Stand-out partners, exceptional.’

Key clients

IFM Investors Pty Ltd.

Hines Interests Limited Partnership

Sunnova Energy Corporation

Liberty Latin America Ltd.

AIP, LLC

McDermott International, Inc.

NRG Energy, Inc.

Pelican Energy Partners II LP

Riverstone Holdings LLC

Golar LNG Partners L.P.

Work highlights

  • Represented IFM Investors in the acquisition of Buckeye Partners, under which the IFM Global Infrastructure Fund will acquire all of the outstanding public common units of Buckeye for $41.5 per common unit.
  • Advised McDermott International on the sale of its Lummus Technology business following a restructuring process.
  • Representing NRG Energy in connection with the pending acquisition of Direct Energy from Centrica for $3.6bn in an all-cash transaction.

Caplin & Drysdale, Chartered

Based in Washington DC, Clark Armitage and Elizabeth Stevens of Caplin & Drysdale, Chartered are experts in transfer pricing matters and APA negotiations between multinational corporate clients and foreign tax bodies across Asia-Pacific, Latin America and EMEA. David Rosenbloom and New York-based Jonathan Breemer are key names for cross-border restructuring matters for trading companies, private equity groups and family offices; while Kirsten Burmester is a name to note for high-net-worth individuals seeking advice on offshore investment and estate structuring and planning. The team also advises international pension funds on real estate investments, and has recently been involved in a number of cross-border M&A in the IT sector.

Practice head(s):

Clark Armitage; David Rosenbloom

Other key lawyers:

Elizabeth Stevens; Jonathan Breemer; Kirsten Burmester

Work highlights

  • Provided an opinion regarding the status under the PATH Act of a mixed public/private Mexican pension plan and established structures for it to invest in US real estate and non-real estate assets.

Clifford Chance

As head of the New York-based international tax practice at Clifford Chance, David Moldenhauer regularly advises global investment management teams on complex tax structures relating to fund formations and associated compensation arrangements. Avrohom Gelber has expertise in domestic and international capital markets issuances; Philip Wagman focuses on international M&A; and Michael Seaton handles REIT IPOs and restructurings for strategic investors including sovereign funds. Also recommended are James Gouwar, who advises on structured products, including MBS and CLOs, and counsel Rebecca Pereira.

Practice head(s):

David Moldenhauer

Other key lawyers:

Avrohom Gelber; Phiip Wagman; Michael Seaton; Rebecca Pereira; James Gouwar

Testimonials

‘The team provides sophisticated tax advice, while being commercial. Clifford Chance understands the different constituents in a deal and provides excellent service/perspective.’

‘Michael Seaton is an elite tax lawyer. He has deep expertise of any real estate tax issues and is very commercial. He is responsive and a top-quality tax advisor.’

Key clients

Apollo Commercial Real Estate Finance Inc.

Berkshire Residential Investments

Colony Capital

Ardian

Global Jet Capital Inc.

Greystone & Co., Inc.

Hearst Corporation

Madison International Realty

National Storage Affiliates Trust

Cantor Fitzgerald

Work highlights

  • Advising private equity house Ardian on the strategic acquisition by its investee company, The Dedalus Group, of DXC Technology’s healthcare software provider business for $525m.
  • Advised ICG Strategic Equity on its acquisition of interests in certain portfolio companies owned by Mid Europa Funds III and IV, and the restructuring of those Mid Europa Funds’ interests in those portfolio companies.
  • Advised Marubeni Corporation and Mizuho Leasing Company on the acquisition of the shares of aviation finance company Aircastle Limited.

Dentons

Dentons handles international tax planning matters for an impressive client base, advising on a range of transactions, as well as on cross-border finance strategies and tax treaty interpretation. Key partners include Washington DC-based practice head John Harrington, who has extensive knowledge of foreign tax credits; New York-based Marc Teitelbaum, who advises on international manufacturing and sales operations; and Timothy Santoli (also in New York), who regularly helps to structure tax-free M&A deals for domestic and international clients. Highlights from the past year have seen the team advising on joint ventures with foreign partners, project financings, privatizations, restructuring of foreign operations. It is also recommended for international investment fund structuring.

Practice head(s):

John Harrington

Other key lawyers:

Marc Teitelbaum; Timothy Santoli

Key clients

Ample Organics

Cam Clark Automotive Group

Brainlab AB

Autonomous Research LLP

Lactalis Group

Hummingbird Ventures

Northern Swan Holdings

Work highlights

  • Provided tax advice to leading dairy group, family-owned French dairy manufacturer Lactalis Group, in structuring and negotiating its acquisition of Kraft Heinz Co.’s natural cheese business and a mix of other cheese brands in North America and internationally for $3.2bn.
  • Provided all US tax advice to colleagues in the Istanbul office representing Hummingbird Venture’s sale of its interests in Peak to Zynga.
  • Advised Northern Swan Holdings, a multinational operator in the cannabis industry, on its combination with Eagle Canada Holdings Clever Leaves, a leading vertically-integrated Colombian licensed producer of pharmaceutical-grade medical cannabis and hemp extracts.

Freshfields Bruckhaus Deringer LLP

Freshfields Bruckhaus Deringer LLP's international tax partners advise financial institutions, private funds, and corporates on a variety of complex cross-border corporate and financing transactions. Key contacts in the team are Robert Scarborough and Claude Stansbury, based in New York and Washington DC, respectively.

Hogan Lovells US LLP

At Hogan Lovells US LLP, Washington DC-based Jasper Howard advises on a high volume of international M&A transactions, particularly in the TMT and defense sectors. Cristina Arumi (also based in Washington DC) and Josh Scala in San Francisco are the team’s REIT experts, handling international tax structuring for non-US investors. In Baltimore, Nancy O’Neil represents private equity investors active in the hotels, technology, media and entertainment, and financial services sectors. The practice group is headed by Siobhan Rausch in Washington DC, who provides a full-range of tax advice to tax-exempt organizations, including public charities, private foundations, universities and health systems. The team also acts for prominent sovereign wealth funds.

Practice head(s):

Siobhan Rausch

Other key lawyers:

Jasper Howard; Cristina Arumi; Josh Scala; Nancy O’Neil

Key clients

Dell

Ford

Intel

Marvell

Kingdom Holding Company

Bell Partners

QTS Realty Trust

Public Storage

VICI Properties Inc.

Park Hotels and Resorts

Work highlights

  • Advised Marvell Technology Group, a publicly traded leader in infrastructure semiconductor solutions, on its $9bn acquisition of Inphi Corp., a publicly traded high-speed data movement platform.
  • Advised Dell on the tax elements of its $2bn sale of RSA to a consortium of investors led by Symphony Technology Group, Ontario Teachers’ Pension Plan Board, and AlpInvest Partners.
  • Advised Ford on the tax elements of the $2.6bn investment by Volkswagen into Ford’s autonomous vehicle platform company, Argo AI, at a valuation of more than $7bn.

Paul Hastings LLP

Paul Hastings LLP’s international tax group leads on inbound transactions from Canada, India and jurisdictions across EMEA. Chicago-based Ziemowit Smulkowski leads the way on private equity-backed investments, while practice head Joseph Opich and David Masko in the New York office tackle securitizations, REITS, restructurings and M&A transactions. Stand-out West Coast partners include Orange County-based Douglas Schaaf and Thomas Wisialowski in Palo Alto, who are retained by tech investors for cross-border tax planning. Wisialowski also represents numerous non-US sovereign wealth funds in inbound investment activity. The group has also witnessed an uptick in repatriation planning of late.

Practice head(s):

Joseph Opich

Other key lawyers:

Ziemowit Smulkowski; David Masko; Douglas Schaaf; Thomas Wisialowski

Testimonials

‘Technically strong, sensitive to cross-border tax rules and cross-cultural implications of cross border-tax work. Proficient and committed to client goals.’

‘A diverse and multicultural team, well versed in multilanguage capabilities.’

‘David Makso has done a wonderful job of not only keeping the team afloat in New York, but rather making it flourish!! David is a pleasure to work with, on top of his game and very pragmatic.’

Key clients

Bank of America

Brookfield Investment Funds

Credit Suisse

Morgan Stanley

PGIM (subsidiary of Prudential Financial, Inc.)

Colony Capital, Inc.

REEF Technologies Inc.

Teachers Insurance and Annuity Association of America

Saba Software

Subversive Capital L.P.

CA Ventures Student Housing Core Fund

Binance

WatchGuard Technologies

SICP LLP

Work highlights

  • Provided tax structuring advice on the formation of a $3.5bn partnership on behalf of an investor group for investment in and expansion of Vantage Data Centers portfolio of data centers across North America and Europe held through tiers of REITs.
  • Advised REEF Technologies on the tax aspects a number of complex financing deals netting the company commitments for close to $750m, which will then be deployed to expand the business and acquire new assets and service contracts.
  • Provided tax structuring advice to Teachers Insurance and Annuity Association of America and its investment manager company, Nuveen Alternatives Advisors, on the formation of an open-ended global farmland fund expected to exceed $2-3bn that will target agricultural investments in selected markets around the world.

Proskauer Rose LLP

Proskauer Rose LLP's international tax group is particularly active in the funds space, reflective of a what is a core strength of the wider firm. In this regard, Amanda Nussbaum in New York and Chicago-based Arnold May, Scott Jones and Stephen Severo advise on tax-forward strategy relating to highly sophisticated fund formation mandates, and also provide ongoing tax advice for transactions throughout a fund's life cycle. The team acts for a huge variety of sponsors, which sees it advising on buyout funds, venture capital funds, mezzanine funds, secondary funds and funds-of-funds. Also recommended in New York are David Miller and Martin Hamilton, who have expertise in cross-border M&A and financing transactions, including the tax treatment of financial products and derivatives.

Practice head(s):

Ira Bogner

Other key lawyers:

Amanda Nussbaum; Arnold May; Scott Jones; Stephen Severo; David Miller; Martin Hamilton

Testimonials

‘Very professional; practical approach; highly recommended.’

‘Martin Hamilton is fast, professional, has excellent knowledge and excellent practical approach.’

Key clients

Arkema Inc.

L Catterton

Grifols S.A.

AccorHotels

GNB Financial Group

J.P. Morgan Securities LLC

British Telecommunications plc

Bessemer Venture Partners

Banco Santander

Work highlights

  • Advised Arbour Lane Capital Management on the closing of Arbour Lane Credit Opportunity Fund II, the manager’s first standalone fund after a spin-off from Credit Suisse in 2016.
  • Advised Barcelona-based life sciences company Grifols on its entry into a definitive agreement to buy Alkahest, a Silicon Valley biotechnology company that is researching clinical uses of plasma proteins in combating diseases associated with aging including Alzheimer’s and Parkinson’s.
  • Advised funds managed by the Credit Group of Ares Management Corporation on the largest ever unitranche financing representing in aggregate £1.8bn commitment to The Ardonagh Group.

Reed Smith LLP

Led by James Tandler and Angelo Ciavarella in New York, Reed Smith LLP’s international tax group handles buy- and sell-side international transactions in a range of industry sectors, including media and entertainment, music publishing, cannabis, transport, insurance and healthcare. Washington DC-based Jeffrey Korenblatt and New York-based David Hryck are the team’s leading transfer pricing experts, while Cheryl Hader (also in New York) focuses on international wealth planning for non-US high-net-worth individuals.

Practice head(s):

James Tandler; Angelo Ciavarella

Other key lawyers:

Jeffrey Korenblatt; David Hryck

Vinson & Elkins LLP

As a leading Texas-based firm, Vinson & Elkins LLP fields an international tax team with substantial capabilities in the oil and gas and energy sectors, though the group also acts for financial services, real estate and technology clients, including SPACs. Department head George Gerachis and John Lynch in Houston and David peck in Dallas advise on project financing, ownership structures, foreign business expansions, cross-border M&A, transfer pricing planning and strategic international tax restructuring. Outside of Texas, Natan Leyva and Gary Huffman in Washington DC advise US-based multinationals. on outbound tax affairs, including foreign tax credits and the BEAT and GILTI regimes.

Practice head(s):

George Gerachis

Other key lawyers:

John Lynch; David peck; Natan Leyva; Gary Huffman

Key clients

Total E&P North Sea UK Limited and Total Oil UK Limited

Buckeye Partners L.P.

Riverstone Holdings L.L.C.

Rubicon Oilfield International

Borealis AG

Drunk Elephant

Macquarie European Infrastructure Fund and its portfolio company, Empark

Marathon Petroleum Company LP

NorthStar Realty Europe Corp

WPT Industrial REIT

Helios Towers, Ltd.

First Quantum Minerals Ltd.

Kohlberg Kravis Roberts & Co. L.P.

CryoLife

Switchback Energy Acquisition Corporation

Blackstone Infrastructure Partners

Work highlights

  • Advised Rubicon Oilfield International, a portfolio company of Warburg Pincus, on its definitive agreement to be acquired by Innovex Downhole Solutions.
  • Advised Switchback Energy Acquisition Corporation, a SPAC sponsored by an affiliate of NGP Capital Management, on its $2.4bn business combination with ChargePoint, a leading electric vehicle charging network.
  • Advised Riverstone Holdings LLC, the Manager of Riverstone Energy Limited, on the formation of Onyx Strategic Investment Management I BV, a newly formed European independent power producer, and its signing of an agreement to acquire a fleet of coal- and biomass-fired power stations from affiliates of ENGIE S.A.

Baker & Hostetler LLP

Baker & Hostetler LLP’s tax team advises on international tax planning and multi-jurisdictional controversies for mid-market US corporates in the financial services, industrial, insurance, technology and manufacturing sectors. Washington DC-based practice heads Jeffrey Paravano and Brian Davis are also recommended for advice on foreign tax credits, BEAT reforms and international tax treaties, as well as strategic advice on inbound and outbound investments, M&A, transfer pricing, redomiciliation exercises and joint ventures. The group has also recently been involved in business restructurings, acting on behalf of executive teams in the life sciences sector.

Practice head(s):

Jeffrey Paravano; Brian Davis

Key clients

Charles G. and Kathleen F. Moore

The Sherwin-Williams Company

Progressive Insurance Company

American Resort Development Association

Work highlights

  • Handling international tax planning, tax controversy and other tax areas for Sherwin-Williams.
  • Representing the American Resort Development Association – Resort Owners Coalition, an advocacy group for time share owners, in challenging an enactment by the US Virgin Islands of an environmental impact fee against the use of time share units by their owners.

Cadwalader, Wickersham & Taft LLP

Cadwalader, Wickersham & Taft LLP’s New York-based international tax practice represents multinational companies and US-based private equity funds in cross-border M&A transactions, typically acting on the buyer side. Practice head Linda Swartz has particular expertise in bankruptcy matters, where she is engaged by creditors—including investment banks, insurance companies and intermediaries—to achieve tax-optimal corporate restructurings. The team handles IPOs and recapitalizations involving offshore-held IP, often for technology companies. Jason Schwartz advises on tax matters relating to securitizations and CLOs.

Practice head(s):

Linda Swartz

Other key lawyers:

Jason Schwartz

Key clients

Alternative Reference Rates Committee (ARRC)

Assured Guaranty Corp.

CVC Capital Partners

Kingsland Holdings Limited

MBIA, Inc.

Numerous Global Banks

Shanda Asset Management

Work highlights

  • Representing Assured Guaranty Corp. and Assured Guaranty Municipal Corp. in connection with the Commonwealth of Puerto Rico’s restructuring of approximately $73bn of outstanding bond debt.
  • Representing MBIA Insurance Corp. and MBIA Inc. in multiple capacities relating to two of three collateral loan obligation investment funds referred to collectively as the Zohar Funds.
  • Representing Kingsland Holdings in the Chapter 11 cases for Avianca Holdings.

Curtis, Mallet-Prevost, Colt & Mosle LLP

Curtis, Mallet-Prevost, Colt & Mosle LLP's international tax heads Marco Blanco and Klas Holm, together with Eduardo Cukier and Olga Beloded, represent international corporates in mid- and upper-market M&A, joint venture structuring, tax-forward reorganizations and international controversies concerning bilateral investment treaties. Investment structuring is another strong point, with investments funds (including sovereign wealth funds), international banks (notably from the Middle East) and asset managers relying on the team for comprehensive tax support in these matters. Named lawyers are based in New York.

Practice head(s):

Marco Blanco; Klas Holm

Other key lawyers:

Eduardo Cukier; Olga Beloded

Key clients

E.ON SE

Unipharm

Brevet Capital Management

Burgan Bank

United Gulf Bank

Government of India

Work highlights

  • Representing long-standing client E.ON SE in a broad range of matters, including a recent $20bn global restructuring involving asset and business swaps across multiple jurisdictions.
  • Acted for the Government of India in connection with a tax dispute involving a bilateral investment treaty arbitration brought by Vodafone against the Government of India over its liability for a $2.6bn tax transfer of assets.
  • Advising Brevet, a large hedge fund and asset manager, on a broad range of matters relating to transactions, the structuring of investments, and cross-border tax issues.

Hughes Hubbard & Reed LLP

Key names for international tax planning at Hughes Hubbard & Reed LLP include practice head Andrew Braiterman, recently promoted partner Alan KravitzSpencer Harrison and Ruben Diaz in Miami. The firm is a prominent player in the aviation space, both in terms of traditional aviation financing, securitizations and equity sales, and in recent fundraising mandates relating to the CARES Act. The team is also experienced in international joint ventures, M&A, spin-offs and a variety of other corporate transactions. Aside from aviation, the group is also active in the areas of entertainment, financial services, life sciences and technology. Named lawyers are based in New York unless stated otherwise.

Practice head(s):

Andrew Braiterman

Other key lawyers:

Alan Kravitz; Ruben Diaz; Spencer Harrison

Key clients

Air Lease Corporation

BAC Florida Bank

Grab Holdings

Griffin Global Asset Management

Infosys

Platinum Equity

The Republic of Paraguay

Roberta Lipson

Sculptor Capital Management

United Airlines Inc.

Wipro Ltd.

Work highlights

  • Represented Platinum Equity, a Beverly Hills-based private equity firm, in its $1.9bn public takeover of Wesco Aircraft Holdings.
  • Represented global information technology leader Infosys in its acquisition of Simplus, the global leader of Salesforce quote-to-cash.
  • Advised United Airlines on a $325m secured convertible financing for Latin American carrier Avianca Holdings, which closed in a series of fundings between December 2019 and January 2020.

Linklaters LLP

David Brockway in Washington DC is the key contact for international tax mandates at Linklaters LLP. Brockway and the team have a solid track record of handling large M&A and international financing deals for global clients including private investment managers and multinational companies.

Miller & Chevalier Chartered

Well known for its expertise in tax controversy and regulatory matters, Miller & Chevalier Chartered is recognized here for advising an impressive roster of long-standing clients on international planning and strategic guidance. A key figure in the team is transfer pricing and tax controversy expert Rocco Femia, who has strong knowledge of BEAT and GILTI policy, and has previously held positions at the US Treasury and the OECD. Layla Asali and Kevin Kenworthy jointly lead the practice group. The former handles M&A and supply chain planning, while the latter is recommended for representation in tax controversies. Also recommended is Loren Ponds, who advises on APA and mutual agreement procedure (MAP) negotiations. The team is based in Washington DC.

Practice head(s):

Kevin Kenworthy; Layla Asali

Other key lawyers:

Rocco Femia; Loren Ponds

Key clients

The Coca-Cola Company

Freeport McMoRan Inc.

Semiconductor Industry Association

Work highlights

  • Secured favorable administrative guidance on behalf of Freeport McMoRan regarding the US federal tax treatment of foreign income that is subject to high foreign effective tax rates.
  • Retained by a multinational technology company to pursue a technical correction to clarify the application of the attribution rules under the Subpart F controlled foreign corporation rules to ensure that the repeal of the so-called “downward attribution” rule does not unintentionally impact common business ownership structures.
  • Advising SIA (the trade association representing the US semiconductor industry) on several topics important to its member companies, including pending legislation regarding the research and experimentation deduction and the application of final regulatory guidance under numerous international tax provisions of the TCJA to the industry.

Norton Rose Fulbright

Headed up by Houston-based Andrius Kontrimas, the international tax group at Norton Rose Fulbright has recently been involved in a number of bilateral APAs, foreign tax refund claims, global supply chain expansions, corporate restructurings and cross-border M&A negotiations. Oil and gas—including onshore and offshore drilling—is the primary sector of focus.

Sullivan & Worcester LLP

The international tax professionals at Sullivan & Worcester LLP assist US-based companies with outbound investments, expansions, restructuring, IPOs and a range of other corporate transactional and operational matters across EMEA and Asia-Pacific. Boston-based practice head Douglas Stransky and Ameek Ponda also have expertise in public REITs, advising on matters including general tax compliance, acquisitions and disposals, equity and debt offerings, and secured and unsecured financing. The team also advises high-profile individuals and executives on cross-border estate planning and pre-residency tax structuring.

Practice head(s):

Douglas Stransky

Other key lawyers:

Ameek Ponda

Testimonials

‘There are three key components that differentiate Sullivan & Worcester. One, response time is incredibly fast. Two, expansive network of handpicked quality contacts in almost every jurisdiction. Three, broad knowledge of subject matter combined with ability to manage multijurisdictional teams of lawyers.’

‘I trust them. They have never steered me wrong.’

Key clients

Broadstone Group, LLC

Halo2Cloud

Iron Mountain Incorporated

Equinix, Inc.

Lionbridge Technologies, Inc.

Altra Industrial Motion

Work highlights

  • Advising Broadstone in connection with the 2021 Summer Olympic Games in Tokyo and the 2028 Summer Olympic Games in Los Angeles.
  • Providing tax counsel and regularly providing public tax opinions to the largest public REIT in the country, American Tower Corporation, and six other large public equity REITs with aggregate market capitalizations exceeding $190bn.

Morrison & Foerster LLP

Morrison & Foerster LLP’s international tax practice is headed by New York-based Anthony Carbone, who advises on M&A, reorganizations, fund formation and capital markets operations. On the West Coast, Bernie Pistillo and recently promoted partner Maureen Linch in San Francisco handle minority investments and equity acquisitions in the financial services, telecoms and digital technology sectors. The team also acts for Palo Alto-based start-ups on outbound business expansion strategies. Also in the recent review period, the group advised multiple media and entertainment companies on tax matters relating to IP restructurings.

Practice head(s):

Anthony Carbone

Other key lawyers:

Bernie Pistillo; Maureen Linch

Key clients

SoftBank Group Corp.

Visa

SoundCloud Limited

Piper Sandler Companies

Carter Validus Mission Critical REIT II, Inc.

Adicet Bio, Inc.

Deutsche Bank Securities Inc.

Sprint Corp.

Steadfast Apartment REIT, Inc.

Barclays Capital Inc.

Temasek Holdings Pte Ltd / Elbrus Investments Pte. Ltd

Alexandria Real Estate Equities, Inc.

Broad Street Realty, LLC

Work highlights

  • Advised SoftBank Group Corp. and SoftBank Vision Fund on tax aspects of the $40bn sale of UK-headquartered multinational semiconductor and software design company Arm Limited to US chip company NVIDIA.
  • Advised Visa on the tax aspects of its acquisition of a minority equity stake in Interswitch Limited, a leading Africa-focused integrated electronic payments and e-commerce company.
  • Advised SoundCloud Limited, developer of a music streaming platform, with tax advice in the $75m minority investment from SiriusXM.

Steptoe & Johnson LLP

Steptoe & Johnson LLP’s Washington DC-based international tax team has expertise in international controversy, government advocacy and tax structuring for high-net-worth individuals. Contacts in the team include Phil West and Robert Rizzi, both of whom advise on cross-border planning, transactions and controversies. West is representing the UK government in a matter concerning the implementation of the Digital Services Tax, involving trade proceedings initiated in the US. Also recommended is Lisa Zarlenga, an expert in tax policy. The team is also noted for its advice on impact assessments for international defense contractors.

Practice head(s):

Phil West; Robert Rizzi; Lisa Zarlenga

Work highlights

  • Advised a high-net-worth individual as an officer and major equity holder in connection with the billion-dollar sale (part cash and part equity rollover) of his business and then a subsequent multibillion-dollar combination and IPO.
  • Providing advice and analysis to a confidential client on a variety of domestic and international tax issues, including analysis of operating agreements, other joint venture structures and corporate structures, as well as advice in connection with foreign, IRS and state and local audits and potential alternative joint venture exit transactions.

Holland & Knight LLP

Thompson & Knight LLP’s international tax group has core strengths in assisting domestic and foreign family offices and businesses with corporate migrations, cross-border estate planning and cross-border transactions, including M&A and joint ventures. Based in Dallas, practice head Todd Keator and Joe Rudberg are particularly active in the oil and gas and energy sectors. The team also provides tax advice on cross-border charitable ventures, including the establishment of foundations and educational programs.

Practice head(s):

Todd Keator

Other key lawyers:

Joe Rudberg

Testimonials

‘Thompson & Knight’s team has a lot of experience in deals with Mexico. In addition to their excellent knowledge of the US tax system they have good knowledge and understand Mexico’s. As a result they can provide a comprehensive service of operations and deals between these two countries.’

Key clients

Oil India Limited

Warwick Capital Partners LLP

Work highlights

  • Provided legal, tax, and employee benefits counsel to Oilfield Water Logistics in connection with the sale of its midstream water infrastructure and services business to InstarAGF Asset Management and its Canadian and international co-investors.

Withers LLP

Withers LLP advises beneficiaries and wealth generators, including ultra-high-net-worth families based across the globe, on the international tax demands of their private capital structures. Standout individuals include co-head William Kambas, who splits his time between Connecticut and New York, Los Angeles-based Michael Brophy and entertainment tax and cannabis industry expert Charles Kolstad, and Michelle Graham in the San Diego office. The group also makes effective use of legal-tech solutions in cross-border estate and succession planning, foreign reporting, intra-family sales and all other tax-efficient strategic operations.

Practice head(s):

William Kambas; Michael Brophy

Other key lawyers:

Charles Kolstad; Michelle Graham; Bryan Kelly; Paul Sczudlo; Megan Jones

Testimonials

‘Their experience in cross-border issues and their ability to understand foreign law issues and apply their local US skills on an international basis.’

‘Michelle Graham has been excellent, very responsive, happy to jump on phone calls and then follow that verbal advice up with practical and yet detailed written advice that is easily understandable to a foreign advisor such as myself, for the benefit of our mutual clients.’

‘The Withers tax practice is largely unparalleled when it comes to international tax matters for international high-net-worth individuals and their families. Its depth and geographic breadth distinguish it from most.’

‘Bryan Kelly and Paul Sczudlo in Los Angeles are leaders in the field. Megan Jones shows great promise and energy.’

‘Always ahead of legal & tax developments; user-friendly approach to complex questions; swift and practical responses on all topics of concern to our private clients; they are truly outstanding.’

‘We have a long-standing relationship with William Kambas. He is highly knowledgeable, efficient, pragmatic and an excellent communicator; a great pleasure to work with.’