Firms To Watch: International tax

Hochman, Salkin, Toscher, Perez P.C. advises US-based high-net-worth individuals and estates on offshore voluntary disclosures regarding foreign financial accounts.
Ivins, Phillips & Barker is a strong choice for transfer pricing, foreign tax credits, and subpart F mandates.

International tax in United States

Baker McKenzie LLP

The international tax team at Baker McKenzie LLP provides a ‘seamless offering‘ to multinational companies on tax planning, tax-related M&A, and transfer pricing matters. In Dallas, practice group chair Melinda Phelan covers international M&A and reorganizations, as well as transfer pricing matters. Based in Washington DC, tax group principal Rafic Barrage advises clients in the software, tech, pharmaceutical, and life sciences industries on tax planning and transactions. Stewart Lipeles operates out of Palo Alto and focuses on international tax planning and tax minimization, as well as tax-related aspects of M&A. He works alongside tax planning specialist Gary Sprague, while in Houston, Jonathan Martin covers tax controversies and international tax planning, while Chicago-based Julia Skubis Weber is noted for advising multinationals on federal income tax planning. Jeff Maydew departed in July 2021.

Practice head(s):

Melinda Phelan; Rafic Barrage

Other key lawyers:

Stewart Lipeles; Gary Sprague; Jonathan Martin; Robert Moore; Julia Skubis Weber

Testimonials

‘Able to pull together resource from around the world to provide a seamless offering for multi-national clients.’

‘Robert Moore in my view is exceptional in the tax field. He has an extraordinary depth of knowledge on a wide range of tax matters. He has a great commercial understanding of what clients need and will be extremely creative to get a solution. He is always available on a short notice. In my view the best tax lawyer in the US.’

Key clients

Merck & Co., Inc.

Equinix, Inc.

Transocean

Mytheresa

Trimble Navigation Limited

Nuance Communications, Inc.

Repsol, S.A.

Naturgy Energy Group, S.A.

Work highlights

  • Advised Merck on the tax aspects of the spin-off of their Women’s Health, trusted Legacy Brands, and Biosimilars businesses.
  • Advised Equinix Inc on the creation of an additional $3.9bn joint venture with GIC to develop and operate 18 data centres across EMEA and South and Central America.
  • Advised Transocean on a transaction to significantly reduce its third party debt load by issuing new debt from a Cayman Islands subsidiary in exchange for outstanding bonds issued by various U.S. and foreign subsidiaries.

Cravath, Swaine & Moore LLP

Cravath, Swaine & Moore LLP is well-regarded for its experience constructing tax-efficient structures for cross-border M&A, spin-offs, SPACs, and private equity funds. In New York, ‘outstanding‘ practice head Lauren Angelilli focuses on tax aspects of cross-border joint ventures and SPACs, M&A, restructurings, and financing transactions. She works alongside Stephen Gordon, who covers international restructurings and joint ventures, as well as general corporate finance; Christopher Fargo, who advises on tax aspects of M&A, securities offers, and reorganizations; and Len Teti, who is highly regarded for his international tax work on behalf of key players in the pharma industry. International tax experts Andrew Davis and Arvind Ravichandran were both elected to partnership in November 2021 and joined the New York tax team in January 2022, while Ronald Creamer Jr. joined from Sullivan & Cromwell LLP in September 2021. Andrew Needham retired in December 2021 while Kara Mungovan departed in November 2021.

Practice head(s):

Lauren Angelilli

Other key lawyers:

Stephen Gordon; Christopher Fargo; Andrew Davis; Arvind Rachandran; Ronald Creamer; Len Teti

Testimonials

‘High quality of tax practitioners. Good technical skills. Easy to work with. Develop good interpersonal relationships. Get to know the business and act as a supportive adviser.’

Excellent project management in very large and complex M&A transactions. Clear and concise communication from the C suite on down. Extremely strong tax technical knowledge including complex cross border matters. Delivered work products on a timely basis.’

Lauren Angelilli is an outstanding tax partner. She has an extremely deep tax technical knowledge. She is able to effectively manage large M&A projects with her team. She is also a very effective communicator and has the ability to effectively explain complex tax matters to senior management.’

Key clients

AerCap

Afterpay

Anglogold Ashanti

Daily Mail

Deutsche Börse

Deutsche Telekom

GW Pharmaceuticals

IBM

Just Eat Takeaway.com

Prosus

Proximo Spirits

The Walt Disney Company

Work highlights

  • Advised AerCap Holdings N.V. in connection with its $30bn acquisition of GE Capital Aviation Services from General Electric.
  • Advised Afterpay Limited in connection with its pending $29bn acquisition by Square, Inc.
  • Advised Daily Mail and General Trust plc in connection with the £1.425bn sale of Risk Management Solutions to Moody’s.

Freshfields Bruckhaus Deringer LLP

Freshfields Bruckhaus Deringer LLP advises investment funds and financial institutions in Europe, Asia, and the Middle East on tax structuring and tax-related issues involving major M&A transactions, carve-outs and demergers, and SPAC formations. Its client base includes major players in the life sciences, fintech, and tech industries. Notably, the team leads on tax-related matters concerning AstraZeneca’s $39bn acquisition of Alexion. Based in New York, practice co-chair Robert Scarborough is an expert in cross-border corporate and financial transactions, and led on the AstraZeneca acquisition, and is noted for his work on SPAC deals. Claude Stansbury operates out of Washington DC and focuses on domestic and cross-border acquisitions, restructurings, disposals, and financings, as well as tax optimization. In New York, Dennis Caracristi deals with complex international tax mandates for leading players in technology and finance.

Practice head(s):

Robert Scarborough; Claude Stansbury

Other key lawyers:

Dennis Caracristi

Key clients

Honeywell

Cargill

Stagwell Media

Continental AG

PepsiCo

Hellman & Friedman

Advent International

Fresenius

Goldfinch Partners

Sandvik AB

CompuGroup

Americold Realty Trust

Emerald Holdings

Flint Group

Zymergen

AstraZeneca plc

Google

CVC Capital Partners

London Stock Exchange

Li-Cycle

Royal Caribbean Cruises

British Telecommunications

Oracle Corporation

Flutter Entertainment

Cazoo

Western Union

Clever Leaves

One Equity Partners

CarLotz, Inc.

Prodigy Finance, Ltd.

Beiersdorf

HPE

Axel Springer

Siemens

America Movil

Honeywell

Cargill

Stagwell Media

Continental AG

PepsiCo

Hellman & Friedman

Advent International

Fresenius

Goldfinch Partners

Sandvik AB

CompuGroup

Americold Realty Trust

Emerald Holdings

Flint Group

Zymergen

AstraZeneca plc

Google

CVC Capital Partners

London Stock Exchange

Li-Cycle

Royal Caribbean Cruises

British Telecommunications

Oracle Corporation

Flutter Entertainment

Cazoo

Western Union

Clever Leaves

One Equity Partners

CarLotz, Inc.

Prodigy Finance, Ltd.

Beiersdorf

HPE

Axel Springer

Siemens

America Movil

Work highlights

  • Advised on tax implications for AstraZeneca during their successful $39bn acquisition of Alexion Pharmaceuticals Inc.
  • Advised London Stock Exchange Group plc on the $27bn acquisition of Refinitiv, including structuring to achieve tax efficient exit for Refinitiv shareholders and tax efficient integration of acquired US and UK groups within LSEG’s worldwide structure.
  • Represented Western Union, the global leader in cross-border, cross-currency money movement and payments, on the tax aspects of the sale of Western Union Business Solutions for $910m in cash to a private equity consortium of Goldfinch Partners and Baupost Group.

Kirkland & Ellis LLP

Kirkland & Ellis LLP is noted for its expertise regarding tax aspects of international M&A, investment fund formation, and restructurings. Practice co-chair Dean Shulman operates out of New York and covers M&A transactions, divestitures, tax-free spin-offs, and real estate investment trusts. Also in New York, Sara Zablotney and David Grenker are key contacts for international tax matters related to transactions and offshore private equity funds, respectively. In Chicago, practice co-chair Todd Maynes focuses on debt restructuring and tax litigation, while Rachel Cantor specializes in tax matters related to cross-border M&A. They work alongside Mike Carew, Lee Morlock, both also in Chicago, and Jared Rusman in New York, well-regarded experts in cross-border tax aspects of M&A transactions. 2021 saw an influx of new partners, including tax structuring specialist Stanley Ramsay from Weil, Gotshal & Manges LLP in May, and transactional tax lawyers Michael Masri and Sophia Han from Orrick, Herrington & Sutcliffe LLP in March and May.

Practice head(s):

Todd Maynes; Dean Shulman

Other key lawyers:

Lee Morlock; Rachel Cantor; Mike Carew; Jared Rusman; Sara Zablotney; David Grenker; Mike Beinus; Stanley Ramsay; Michael Masri; Sophia Han

Testimonials

K&E has a very deep talent pool in pretty much all the countries in which Sun does business. In addition, they have a culture or being commercial. As a result, we are able to call on knowledgeable local professionals with technical capabilities in all business aspects important to us (e.g., tax, benefits, business, privacy, etc.).’

Key clients

Abry Partners

AJAX I

Atlas UK Bidco Limited (Allied Bidco)

Bain Capital

CC Neuberger Principal Holdings I/CC Capital

Celanese Corporation

Cushman & Wakefield

GlobalLogic

Grunhub Inc.

Intelsat S.A.

Ivanhoe Capital Acquisition Corp.

Investor Consortium – Ocean Link Partners and Sequoia Capital China

Knighthead Capital Management/Certares Opportunities

Koninklijke Ahold Delhaize

Lone Star Funds

Neiman Marcus Group (NMG)

Nordic Capital

Pamplona Capital Management-backed Parexel

The Carlyle Group

Work highlights

  • Advised Abry Partners and its portfolio company, Options Technology on the tax aspects of its carve-out acquisition of the U.S. and U.K.-based Fixnetix from DXC Technology.
  • Advised AJAX I on the tax aspects related to its $7bn business combination with Cazoo.
  • Advised Atlas UK Bidco Limited on the tax aspects of the financing for the $5.3bn acquisition of the entire issued and to-be-issued share capital of G4S.

Mayer Brown

Mayer Brown is a strong choice for multinationals, financial institutions, and funds on tax matters concerning inbound and outbound M&A, structured financing and investment funds, transfer pricing agreements, and global tax planning. The team is also involved in multi-jurisdictional ‘bet-the-company’ tax disputes. Co-chair and tax planning specialist Jason Bazar is based in New York. He works alongside Lucas Giardelli, a specialist in international tax planning. In Chicago, global co-chair James Barry covers tax planning regarding restructuring and acquisitions, while Michael Lebovitz and Thomas Kittle-Kamp deal with transfer pricing agreements and corporate reorganizations. In Washington DC, Kenneth Klein advises on both tax structuring and restructuring for Fortune 100 companies. He works alongside international tax controversy expert Gary Wilcox and Jason Osborn, who is noted for his work on transfer pricing and bilateral advance pricing agreements. 2021 saw a number of new partners joining the practice: tax transaction specialists Greg Matlock from Ernst & Young in January and Michelle Jewett from Stroock & Stroock & Lavan LLP in March; tax controversy attorney Jenny Austin from Morgan, Lewis & Bockius LLP in May; and CFIUS filing specialist Amanda Rosenberg from Norton Rose Fulbright in August. Andy Baik departed in September 2021.

Practice head(s):

Jason Bazar; James Barry

Other key lawyers:

Michael Lebovitz; Tom Kittle-Kamp; Kenneth Klein; Jason Osborn; Gary Wilcox; Lucas Giardelli; Greg Matlock; Michelle Jewett; Jenny Austin; Amanda Rosenberg

Testimonials

Mayer Brown’s international tax practice is very experienced in representing clients before the Competent Authority of the U.S. in treaty controversies. They are well respected by APMA, and as well are known and trusted by the Competent Authorities of major U.S. treaty partners.’

Jason Osborn has been superb in representing us before APMA in a major controversy with a treaty partner now spanning four decades. A key quality of Jason’s is that he anticipates what both the client and the taxing authority are expecting, thereby saving time in crafting responses.’

Mayer Brown is a great firm, I think they are very efficient and knowledgeable. They have provided accurate advice to the company I work for.’

Lucas Giardelli is a very smart partner, he coordinates with other colleagues in order to provide the necessary advice. Kenneth Klein is another smart partner, he has a lot of experience and his advice has been very helpful to the company.’

Key clients

Caterpillar

CDK Global, Inc.

Ember Infrastructure Partners and ReEnergy Holdings, LLC

GSS Holdings Liberty, Inc / Scotia Bank

World Shipping Council

Brookfield Infrastructure

Kakao Entertainment

HPS Investment Partners LLC

MJX Asset Management LLC

Nestle

Work highlights

  • Represented the World Shipping Council in the possible application of the OECD “Pillar One” and “Pillar Two” digitalization proposals.
  • Represented CDK Global, Inc. in the $1.45bn sale of its CDK international segment to private equity firm Francisco Partners Management, L.P.
  • Represented Caterpillar in its $405m acquisition of the global Oil & Gas Division of The Weir Group plc.

Skadden, Arps, Slate, Meagher & Flom LLP

The international tax expertise at Skadden, Arps, Slate, Meagher & Flom LLP ranges from international and cross-border M&A transactions and restructurings to joint ventures, spin-offs, and energy project finance transactions. Based in Washington DC global tax group head Eric Sensenbrenner specializes in cross-border M&A, post-acquisition restructuring, capital markets transactions, and spin-offs. He works alongside Hal Hicks, an expert in foreign tax credits, transfer pricing, subpart F, and international M&A. Head of the New York team Steven Matays works on tax matters concerning structuring financial instruments, complex debt and equity offerings, and joint ventures. Also in New York, David Rievman focuses on cross-border restructurings and recapitalizations, while Gavin White handles international public and private acquisitions and bankruptcy reorganizations.

Practice head(s):

Eric Sensenbrenner

Other key lawyers:

Hal Hicks; Steven Matays; David Rievman; Gavin White

Key clients

The Coca-Cola Company

Mars Incorporated

Ford Motor Company

Citrix Systems, Inc.

MorphoSys AG

PPL Corporation

Credit Karma

Alcon Inc.

Fortive Corporation

Total Produce plc

SL Green Realty Corp.

NVIDIA

Asia Pacific Land Inc.

GBT Travel Services UK Limited

Work highlights

  • Advised The Coca-Cola Company on complex multi-jurisdictional tax issues implicated in transactions.
  • Advised Mars Incorporated, Ford Motor Company and Citrix Systems, Inc. on several complex and cross-border transactional tax matters.
  • Represented SK hynix, Inc. in its $9bn acquisition of the NAND memory and storage business of Intel Corporation.

Cleary Gottlieb Steen & Hamilton

Cleary Gottlieb Steen & Hamilton is linked to fourteen foreign offices to provide global tax coverage to its clients regarding high-value M&A and international funds. The team covers a wide range of matters, including OECD programmes, US tax reform, and BEAT rules. Its large capital markets practice represents underwriters and issuers, particularly sovereign issuers. Based in New York, practice co-lead Jason Factor is noted for his tax advice to private equity and hedge funds, as well as international acquisitions. He works alongside co-lead Diana Wollman, a cross-border tax-related transactions and controversy specialist and Leslie Samuels, an expert in international transactional tax matters. Also of note in the New York office are William McRae and Meyer Fedida, specialists in US tax structuring of investments for sovereign investors and cross-border tax planning, respectively.

Practice head(s):

Jason Factor; Diana Wollman

Other key lawyers:

William McRae; Meyer Fedida; Leslie Samuels

Key clients

Warburg Pincus

Astound Broadband

SoftBank Group International

Artius Acquisition Inc.

ArcelorMittal

Brookfield Asset Management

American Express

Global Healthcare Exchange

ITOCHU International Inc.

International Seaways

Vivendi

TPG

KKR

Sixth Street

The Carlyle Group

Work highlights

  • Advised Allied Universal, a Warburg portfolio company, in its £3.8bn acquisition of G4S.
  • Advised Cascade Investment in the acquisition of Signature Aviation, as part of a consortium with Blackstone and Global Infrastructure Partners.
  • Advised Brookfield Asset Management in the chapter 11 restructuring of a major publicly traded hospitality REIT and its operating partnership.

Debevoise & Plimpton LLP

Based in New York, Debevoise & Plimpton LLP advises multinationals active in sectors such as banking, private equity, technology, healthcare, and insurance on cross-border tax-related issues. Its expertise ranges from international M&A transactions and public and private financings to private equity and hedge fund formations. Practice co-chair Peter Schuur focuses on corporate transactions for key players in the insurance industry, as well as international investment platform structuring and formation. Practice co-chair Peter Furci covers cross-border M&A, financings, and debt and equity securities offerings. Rafael Kariyev is an expert in the formation of private investment funds and Gary Friedman specializes in multi-jurisdictional M&A and financings. Michael Bolotin is especially strong in cross-border real estate joint ventures and the formation of real estate investment trusts, while Erin Cleary is noted for her work on the formation of international private equity funds. Daniel Priest is also recognized for advising international private equity funds.

Practice head(s):

Peter Furci; Peter Schuur

Other key lawyers:

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

Key clients

American International Group

Assurant, Inc.

The Blackstone Group

Clayton, Dubilier & Rice

Core & Main

Discovery Communications Inc.

Domtar Corporation

Huntsworth

International Paper

JP Morgan Investment

Massachusetts Mutual Life

Metropolitan Life Insurance Company

Mobilux Acquisition

Prudential Financial

Prudential PLC

Schneider Electric Holdings, Inc.

Solenis LLC

Work highlights

  • Advised Discovery Communications Inc. in its acquisition of WarnerMedia from AT&T in a transaction valued at $130bn.
  • Advised Schneider Electric in its acquisition of a strategic approximately 30 percent stake in Uplight, Inc.
  • Advised International Paper on the separation of its printing papers segment in a transaction that will create two separate public companies.

Dentons

Dentons advises high-net-worth-individuals and multinationals on international tax matters globally, including financing corporate subsidiaries, adhering to transfer pricing regulations, corporate income taxes, and indirect tax. It is also experienced with tax-related issues concerning foreign acquisitions, maximizing US foreign tax credits, and providing counsel to US citizens and residents on becoming tax residents of foreign jurisdictions. Based in Washington DC, practice head John Harrington is an expert in inbound and outbound transactional and tax compliance, as well as foreign tax credits and subpart F. In New York Timothy Santoli focuses on taxable and tax-free M&A and dispositions. Linda Pfatteicher joined the San Francisco office from Squire Patton Boggs in June 2021. She specializes in international tax for corporations, including global transfer pricing strategies and intangible property planning. Marc Teitelbaum retired in 2021.

Practice head(s):

John Harrington

Other key lawyers:

Timothy Santoli; Linda Pfatteicher

Testimonials

The Dentons International tax practice provide practical, relevant, business-focused, specific advice and counsel that allows us to easily imply their advice to our potential deals and plan for a more tax-efficient result.’

Tim Santoli is responsive and meets deadlines, providing very practical, business-friendly advice and counsel required for us to accomplish our goals in our deals.’

Key clients

Lactalis Group

PayPal

Work highlights

  • Advised Lactalis Group in structuring and negotiating its acquistion of Kraft Heinz Co.’s (KHC) US natural cheese business and a mix of other cheese brands in North America and internationally for $3.2bn.
  • Advised PayPal in its acquistion of Tel Aviv-based Curv.

DLA Piper LLP (US)

DLA Piper LLP (US) is known for providing global tax planning and transactional advice, as well as tax controversy services. The ‘very knowledgable‘ team covers such areas as post-acquisition integration and global equity. Global tax practice chair Sang Kim is based in Silicon Valley and advises on global transfer pricing strategies, joint ventures, and M&A. In New York, Philip Rogers specializes in international tax planning and operational structuring, Kevin Glenn deals with international tax controversy, Frank Mugabi focuses on public cross-border M&A, and Maruti Narayan is an expert in international tax structuring and planning. Based in Los Angeles, David Cook is particularly strong in global transfer pricing and international tax planning and structuring. In Silicon Valley, Ben Olivas is a key name for international tax and cross-border M&A. Principal economist Masa Kuramoto and counsel Carlos Vaca Valverde joined from Ernst & Young LLP in April 2021. Sibel Owji departed in October 2021, while Michael Hardgrove departed in June 2021.

Practice head(s):

Sang Kim

Other key lawyers:

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

Testimonials

‘The DLA tax team is very knowledgeable and thoughtful but also very responsive and flexible to our needs as the client.’

‘In the world of tax planning, I look primarily for advisors who can show a high level of technical expertise and creativity. Kevin Glenn is one of the most insightful practitioners I have worked with. Beyond being a true subject matter expert, he also frequently comes up with ideas/structures that leave me thinking . . . “I wish I had thought of that!”’

‘The team is both tactical and strategic. I appreciate the innovative solutions to business issues and ability to partner to get things done.’

‘The partners are there for your success. They’re excellent business partners. Kevin Glenn has stood out as someone who is always creatively thinking about our issues and is both creative and practicable at same time.’

DLA US team ensures a global approach towards tax and legal and makes sure that all workstreams are aligned with the common goal/project. This saves time for us, as a client. Solid tax and legal knowledge and they bring a good spirit.’

The team that works on our account is very technical. They helped us navigate through the various complex tax reforms globally. Our company has been expanding rapidly and has benefited from their global legal/tax network and their support is above par.’

Key clients

Danaher Corporation

Moody’s

MKS Instruments, Inc.

International Flavors & Fragrances

HB Fuller

Pfizer

SANOFI

Hewlett Packard Inc

HP Enterprise

Macquarie

Insmed

Whirlpool Corp.

Deutsche Bank

General Electric

Ford

Cold Chain Technologies

Catalent Pharma Solutions

Teleflex

Masimo

Take Two

Work highlights

  • Advised Moody’s Corporation on a range of legal and operational matters such as legal entity rationalizations and tax policy.
  • Advised MKS Instruments, Inc. in connection with the potential acquisition of a foreign company.
  • Advised on and implemented post-acquisition integration plans for International Flavors & Fragrances.

Eversheds Sutherland

Eversheds Sutherland advises major international corporates based in both the US and abroad on tax-related international transactions, covering areas such as FATCA, IGAs, and OECD. The team is particularly strong in international tax structuring work, global minimum tax, and US tax reform. In Washington DC, newly-appointed practice leader Robert Chase deals with acquisitions, spin-offs, restructurings, and transactions. He works alongside Aaron Payne, an expert in domestic and international tax planning, transactions, and compliance, as well as Caroline Setliffe, a specialist in tax treaties and transfer pricing issues in light of OECD. Based in New York, Bruce Wright covers the intersection of tax and insurance matters, as well as the captive insurance industry and the formation of commercial offshore privately and publicly-held entities, while Saren Goldner is noted for her work on reinsurance and insurance tax matters. DC-based  Mary Monahan was recently appointed deputy practice leader, and advises on international tax planning for acquisitions, restructurings, and tax treaties. Jonathan Sambur, a specialist in international information reporting requirements, joined from Mayer Brown LLP in April 2021.

Practice head(s):

Robert Chase

Other key lawyers:

Aaron Payne; Caroline Setliffe; Saren Goldner; Bruce Wright; Mary Monahan; Jonathan Sambur

Key clients

Vitol

Chemoil Corporation

Deutsche Börse AG

Work highlights

  • Represented Vitol, Inc. in litigation involving the alternative fuel mixture credit.
  • Represented 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.

McDermott Will & Emery LLP

McDermott Will & Emery LLP advises multinationals on tax aspects of international M&A transactions, transfer pricing, and corporate restructuring. The team is also highly experienced in tax planning and advisory work, as well as advising high-net-worth individuals in complex multi-jurisdictional tax disputes and litigation. In Washington DC practice leader Tim Shuman is an expert in cross-border acquisitions, restructurings, and dispositions. He works alongside international tax planning expert Caroline Ngo  and Britt Haxton, a specialist in tax-free and taxable acquisitions, restructurings, and liquidations. Operating out of Chicago, Damon Lyon deals with cross-border M&A and international tax controversies, Brian Jenn covers US taxation of foreign currencies and transfer pricing, and Lowell Yoder focuses on cross-border M&A and global tax planning. In Miami, Michael Silva advises on cross-border transactions. The team expanded in 2021 with international tax planning specialists Alex Farr joining from Weil, Gotshal & Manges LLP in February, Michael Hardgrove joining from DLA Piper LLP (US) in May, and Jeff Maydew and Meaghan Wolfe joining from Baker McKenzie LLP in July. Lauren Ferrante and Alysse McLoughlin departed in January and August 2021.

Practice head(s):

Tim Shuman

Other key lawyers:

Caroline Ngo; Britt Haxton; Damon Lyon; Brian Jenn; Lowell Yoder; Michael Silva; Alex Farr; Michael Hardgrove; Jeff Maydew; Meaghan Wolfe

Testimonials

‘This has been my first engagement with the McDermott team and it was an exceptional experience. The knowledge about technical topics and collaboration with our team was more than I have ever experienced in my 16 years of work in tax. The team always had someone available to discuss topics or join calls. Their ability to work together behind the scenes was extraordinary as the entire team was always up to speed and prepared for discussions/meetings.’

‘Very efficient and customized advice with a wide breadth of expertise.’

‘Trusted business advisor in tax and legal matters. Excellent relationship build-up capabilities, sustained by superb technical knowledge, communication with impact, fast responsiveness, ability too tackle sensitive areas. Great ability to connect and bring relevant experts in the picture when needed. World-class services.’

They are highly responsive. We have referred some individual clients to them, and the feedback and the interaction with us could not be better. We are sure that our clients are being well advised regarding their investments in the US.

MWE’s International Tax experience is superb, their team is well diversified with individuals that have experience in all fields of international tax. The have individuals fluent in different languages and working experience in different countries. Their client base is large enough to expose them to new and unique cases.’

The MWE team is the best I have ever had the pleasure of working with – their collaboration and connection behind the scenes is clear in the value they provide consistently across the board.’

Tim Shuman is the best client service partner / advisor I have worked with in my tenure as a tax professional. He and his team are no distinguisher of person and treat everyone on the client’s team as the most important person they are dealing with. Hands down, no better way to treat my team and I so appreciate it.’

Caroline Ngo is highly effective at working as part of a real team with the company. She listens and communicates well and understands the company’s business context and planning personality. It is easy to rope her in, have her quickly grasp the issues, and receive advice and helpful suggestions that are on point and reliable. She uses firm resources well, drawing in other talent in an efficient and helpful way without trying to overdo anything.’

Key clients

Coty

Chevron

Illinois Tool Works Inc. (ITW)

Bank of America Securities, Inc.

Procter & Gamble

Viking Global Investors

Work highlights

  • Advised Coty on U.S. tax aspects of the sale of its professional and retail hair business – including the Wella, Clairol, OPI and ghd brands – to the private equity giant KKR for $2.5bn.
  • Advised Chevron in connection with its announced $13bn all-stock acquisition of Noble Energy.
  • Represented Panera Bread (JAB Holding Company) as tax counsel in connection with its announced IPO and the merger of a newly formed subsidiary of Panera with USHG Acquisition Corp.

Paul, Weiss, Rifkind, Wharton & Garrison LLP

Based in New York, the multidisciplinary tax team at Paul, Weiss, Rifkind, Wharton & Garrison LLP is particularly strong on the intersection of US-Canadian, European and Asian tax law. It frequently advises on major M&A, private equity deals, SPACs, and securitizations. Practice co-chair Brad Okun focuses on tax matters connected to high-value M&A and restructurings, while co-chair Scott M. Sontag deals with cross-border restructurings and securitzations. They work alongside Jeffrey Samuels, a specialist in international tax issues related to high-value public transactions; M&A  and joint ventures expert Brian Grieve; and Robert Holo, an expert on tax-free reorganizations and SPAC deals. International transactions specialist Lindsay Parks was recently appointed deputy chair of the team, and David W. Mayo advises on corporate and partnership taxation and tax-free M&A. Additionally, cross-border tax specialist Brian Krause joined from Skadden, Arps, Slate, Meagher & Flom LLP in April 2021.

Practice head(s):

Brad Okun; Scott M. Sontag

Other key lawyers:

Jeffrey Samuels; Brian Grieve; Robert Holo; Lindsay Parks; David W. Mayo; Brian Krause

Key clients

Apollo Global Management

General Atlantic

Chevron Corporation

Fortress Investment Group

General Electric Co.

IBM Corporation

IG Group

Lehigh Hanson

PRA Health Sciences

KPS Capital Partners

Golden Gate Capital

Brighton Park Capital

Univision Holdings, Inc.

Crestview Partners

Silver Lake

Churchill Capital Corp.

Algoma Steel

Intelsat S.A.

Ligado Network

Diamond Offshore Drilling, INc.

Work highlights

  • Advised Apollo Global Management in a variety of its transactions, including fundraising, investments and related portfolio company matters.
  • Advised General Atlantic in a variety of its transactions, including its $800m Series C investment in Mollie.
  • Advised Chevron Corporation in its all-stock acquisition of Noble Energy Inc. at a total enterprise value of $13bn.

Proskauer Rose LLP

The team at Proskauer Rose LLP is particularly strong on cross-border tax structuring, finance, and fund formation. In New York, practice head Ira Bogner advises on tax aspects of executive compensation arrangements. He works alongside David Miller, an expert in taxation of financial instruments; Martin Hamilton, a key resource regarding cross-border investments; and Amanda Nussbaum, a specialist in tax structuring of real estate transactions. In Boston, Arnold May, Stephen Severo, and Scott Jones advise private equity fund managers on fund-raising and investments. Corporate tax expert Robert Friedman joined from Troutman Pepper in October 2021 while international fund formation specialist Daniel Paulos joined from KPMG in September 2021. Janicelynn Park was promoted to partner in November 2021, and focuses on tax implications for private investment funds.

Practice head(s):

Ira Bogner

Other key lawyers:

David Miller; Amanda Nussbaum; Arnold May; Scott Jones; Stephen Severo; Martin Hamilton; Robert Friedman; Daniel Paulos; Janicelynn Park

Testimonials

‘Out of the box, solution oriented. Strong thinkers that are able to marry business goals with transaction structure. Very diligent and hyper focused on the underlying legal documentation to protect us as investors. Our relationship and engagement has been entirely virtual and remote. Has not disrupted our interaction and believe we have very strong, consistent communication. Would strongly recommend the Proskauer tax  team.’

‘Amanda Nussbaum is one of the most creative attorneys we have had the pleasure of working with. She is out of the box, creative thinker that identifies issues but proactively propose solutions. Very creative, pragmatic, and knowledgeable.’

Would strongly recommend.’

Key clients

Accor

Ares Management

Arkema, Inc.

Banco GNB Paraguay, S.A.

Bolloré Group

Converium Capital

Ellington Management Group

Evolution Credit Partners Management

GIC

Grifols S.A.

Morgan Stanley Capital Partners

Work highlights

  • Represented Arkema in its agreement to acquire the performance-adhesives unit of Ashland Global Holdings Inc. for $1.65bn.
  • Advised Ares Management on the final closing of Ares Pathfinder Fund, L.P. and in their acquisition of a 33.96% interest in Atlético HoldCo, S.L.
  • Advised Accor in the sale of a 1.5% stake in Huazhu Group Limited for €239m; the launch of a global strategic partnership with Faena Group; and the creation, structuring and implementation of its global joint venture with Ennismore.

Shearman & Sterling LLP

Shearman & Sterling LLP is is noted for strategic tax advisory and planning work in jurisdictions such as the US, UK, Germany, and France, while the team also advises on international tax structuring, restructuring, and tax controversy matters. It also has expertise in cross-border M&A, and has previously advised private equity and sovereign wealth funds. Based in New York, practice co-head Michael Shulman provides tax advice to onshore and offshore investment funds on transactions. Splitting his time between New York and Menlo Park, co-head Larry Crouch deals with transactional work and planning, particularly on behalf of private equity sellers and buyers. In Washington DC Kristen Garry specializes in cross-border structured finance transactions and capital markets offerings, Jay Singer covers international M&A and spin-off transactions, and Kevin Dolan focuses on cross-border tax matters.

Practice head(s):

Michael Shulman; Larry Crouch

Other key lawyers:

Kristen Garry; Jay Singer; Kevin Dolan

Key clients

Ardagh Group S.A.

Lanxess Corporation

ViacomCBS Inc.

Hitachi, Ltd.

TELUS International

HalioDx

Mubadala Investment Company

DBAG Fund VI and Deutsche Beteiligungs AG

Abertis Infraestructuras, S.A. and Manulife Investment Management

Boston Scientific

OMERS Infrastructure Management Inc.

Bunge Limited

Coca-Cola European Partners plc (Coca-Cola Europacific Partners plc)

Morgan Stanley

BofA Securities

Citigroup Global Markets

Goldman Sachs

J.P. Morgan Securities

Celanese Corporation

Province of Córdoba and Banco de la Provincia de Córdoba

The Nature Conservancy (TNC)

Work highlights

  • Advised Ardagh Group S.A. on its definitive business combination agreement with Gores Holdings V, Inc., a special purpose acquisition company sponsored by an affiliate of The Gores Group.
  • Advised Hitachi, Ltd. in its acquisition of GlobalLogic Inc.
  • Advised TELUS International (Cda) Inc. in connection with its $925m cross-border initial public offering of 42.55m subordinate voting shares.

Simpson Thacher & Bartlett LLP

Based in New York, Simpson Thacher & Bartlett LLP advises multinationals, investment funds, and banks on tax matters related to major financings, capital markets and M&A transactions, and restructurings. The team also provides tax advice to international real estate investment funds. Co-head of the tax practice Nancy Mehlman is noted for her work in tax matters involving fund formation and investments, and is especially strong advising tax-exempt organizations such as universities and private foundations. Marcy Geller has been promoted to co-head and covers REITs, M&A, and fund formation. She works alongside Russell Light, a specialist in tax matters related to M&A, REITs, and SPACs, as well as Sophie Staples, an expert in M&A, dispositions, and divestitures. Jonathan Goldstein is a key resource for private investment fund formation and tax aspects of M&A. Additionally, international tax planning advisor Benjamin Rippeon joined from Gibson, Dunn & Crutcher LLP in March 2021.

Practice head(s):

Nancy Mehlman; Marcy Geller

Other key lawyers:

Russell Light; Sophie Staples; Jonathan Goldstein; Benjamin Rippeon

Key clients

Alibaba Group

Apax Partners

Apollo Global Management

The Blackstone Group L.P.

The Carlyle Group

Centerbridge Partners

Dell Technologies Inc.

Digital Colony

EQT

GFL Environmental

Hellman & Friedman

Hilton Worldwide

Ingersoll Rand

Johnson Controls

J.P. Morgan

Kohlberg Kravis Roberts & Co., L.P.

Lightyear Capital

Macquarie Capital

Microsoft Corporation

New Mountain Capital

People’s United Bank

Rockpoint Group

Silver Lake

The Toronto-Dominion Bank

Versum Materials

ZoomInfo Technologies

Work highlights

  • Represented The Bountiful Company in its acquisition by Nestlé for $5.75bn.
  • Represented Stonepeak Infrastructure Partners in its definitive agreement to acquire the Latin American business of Lumen Technologies, Inc. for $2.7bn.
  • Represented BlackRock’s Global Energy & Power Infrastructure team in its take-private of GasLog.

Weil, Gotshal & Manges LLP

Weil, Gotshal & Manges LLPComparative Guides promotional icon advises sovereign wealth funds and pension funds on tax matters concerning cross-border M&A, restructuring, and bankruptcy. The team also covers international tax planning and obtains favorable rulings from the IRS and European and Asian tax authorities. Based in Washington DC, practice head Devon Bodoh is noted for his work on tax-related issues concerning cross-border M&A spin-offs, SPAC IPOs and de-SPAC transactions. In New York Kimberly Blanchard advises on international restructurings, joint ventures and M&A, while Greg Featherman is a specialist in foreign tax credits, cross-border M&A, and spin-offs. The team has seen a recent influx of partners, including fund formation expert Andrew Morris from Linklaters LLP in November 2021, private equity specialists Jason Vollbracht from Deloitte Global Services Ltd in September 2021 and Hillel Jacobson from Willkie Farr & Gallagher LLP in April 2021, and REIT expert David Levy from Skadden, Arps, Slate, Meagher & Flom LLP in March 2021. Additionally, Stanley Ramsay and Mark Schwed departed in May and April 2021.

Practice head(s):

Devon Bodoh

Other key lawyers:

Kimberly Blanchard; Greg Featherman; Andrew Morris; Jason Vollbracht; Hillel Jacobson; David Levy

Testimonials

‘Very creative in thinking, highly technical, and able to bring ideas to economic impact to client.’

‘It is rare that the level of technical skills can also translate into basics that a C suite can understand economic and even financial statement impact.’

‘They can solve problems other firms cannot.’

‘Devon Bodoh is incredibly responsive and creative.’

‘Kim Blanchard is a top advisor with excellent experience across a wide range of technical tax items and transaction structure.’

‘Kim Blanchard is a legend of US and international tax.’

Key clients

24 Hour Fitness Worldwide Inc.

Advent International

Aleph Capital

Allego Holding B.V.

American Securities

Amherst Holdings, LLC

Ardian

Austerlitz Acquisition Corporation

Cardtronics plc

Cobham Limited

CPP Investments

Culligan International Company

CVC Capital Partners

Crestview Partners, L.P.

Deep Lake Capital Acquisition Corp.

Deluxe Corporation

Depop Limited

EO Charging

Eurazeo

Foley Trasimene Acquisition Corp.

Goldman Sachs

The Gores Group

The Government of the United Kingdom

Hologic, Inc.

ICG Strategic Equity

J.C. Flowers

Kainos Capital

Kantar Group

Lee Equity Partners

LTS (Jorge Paulo Lemann Fund)

Marquee Raine Acquisition Corp.

Mubadala

OMERS

Ontario Teachers’ Pension Plan

Poppulo

PSG

PSP Investments

Restaurant Brands International

Sanofi

Speedcast

SumUp Payments Limited

Vonage Holdings

Wejo Limited

Work highlights

  • Advised Foley Trasimene Acquisition Corp. II on the tax aspects of a $9bn business combination with Paysafe Limited, a specialized payments platform with an international presence. The transaction included a $2bn private placement in public equity to finance, in part, the business combination with Paysafe Limited.
  • Advised Allego Holding B.V. (The Netherlands) (a portfolio company of Meridiam Infrastructure Partners), an operator of a major pan-European electric vehicle (EV) charging network that, at the time, had deployed over 26,000 charging ports across 12,000 public and private locations, in 12 European countries, on the tax aspects of its pending $3.14bn business combination with Spartan Acquisition Corp. III, a SPAC sponsored by Spartan Acquisition Sponsor III LLC (an affiliate of Apollo Global Management) that was focused on the energy value-chain.
  • Advised Wejo Limited (United Kingdom), a provider of organized, analyzed and enhanced streams of connected in-vehicle data to automotive manufacturers, traffic analysts, parking app developers, smart city planners and governments, on the tax aspects of its pending $1.1bn business combination with Virtuoso Acquisition Corp., a SPAC sponsored by Virtuoso Sponsor LLC.

Allen & Overy LLP

The international tax team at Allen & Overy LLP is noted for advising governments, financial institutions, and multinationals on the tax aspects of cross-border corporate transactions, joint ventures, and divestitures and separations. The team is particularly strong regarding FATCA, real estate transactions, and hedge fund work. Dave Lewis is the managing partner of the New York office and specializes in international tax planning, M&A, and private equity transactions. He works alongside Jack Heinberg, head of the US tax group and expert in international tax planning and cross-border financing. Senior counsel Caroline Lapidus is based in Silicon Valley and is a key contact regarding the taxation of global capital markets and real estate transactions.

Practice head(s):

Dave Lewis; Jack Heinberg

Other key lawyers:

Caroline Lapidus

Testimonials

‘Approachable, proactive and technically very sound.’

Jack Heinberg is approachable and proactive, good technical knowledge.’

Key clients

SHV Interholding AG

Pendal Group Limited

Carvana

Blue Road Management

Stonepeak Infrastructure Partners

Macquarie Asset Management

Intralot Capital Luxembourg SA

Société Générale

Morgan Stanley

Work highlights

  • Advised SHV Holdings N.V. on the $360m sale of Makro Peru, a food wholesale provider, to InRetail Peru Corporation, a company listed in Peru.
  • Advised Pendal Group, the ASX-listed Australian asset manager, on its agreement to acquire Thompson, Siegel & Walmsley for $320m.
  • Advised Stonepeak on a public securitization of debt facilities secured by aircraft leases.

Baker Botts L.L.P.

The international tax team at Baker Botts L.L.P. is particularly strong in advising investment funds, energy companies, and manufacturers on international tax planning and restructuring, as well as tax minimization on earnings from investments and dispositions. However, it is also active in the transactional space, including advising on joint ventures, restructurings, and financings. Based in Houston, Derek Green covers cross-border M&A, optimal cross-border leasing structures, and post-merger restructurings. He works alongside Jon Lobb, who often advises clients operating in natural gas and other international energy projects on tax-related matters concerning international M&A. Ron Scharnberg departed in March 2021.

Practice head(s):

Derek Green

Other key lawyers:

Jon Lobb

Key clients

Liberty Media Corporation

Sunna Energy Corporation

Midcoast Energy, LLC

Hines Interests Limited Partnership

Centerpoint Energy, Inc.

Corterra Energy, Inc.

Schlumberger Limited

Noble Corporation

Koch Industries, Inc.

Liberty Latin America Ltd.

Westlake Chemical Corporation

Work highlights

  • Advised Liberty Latin America on the pending formation of a 50/50 joint venture with América Móvil S.A.B. de C.V. to combine their respective Chilean operations, VTR and Claro Chile.
  • Advised Golar LNG Limited on the $3.1bn sale of Hygo Energy Transition Ltd. And the $251m sale of Golar LNG Partners LP to New Fortress Energy Inc.
  • Advised Westlake on the $2.15bn acquisition of Boral Limited’s North American building products business.

Caplin & Drysdale, Chartered

Based in Washington DC, the international tax team at Caplin & Drysdale, Chartered advises on outbound and inbound tax planning and structuring, as well as BEAT exposure. It is particularly strong in transfer pricing disputes, representing clients before foreign tax authorities, and advising on all forms of international tax controversies. Practice co-lead Clark Armitage focuses on international tax planning and controversy, extending to optimizing transfer pricing outcomes and defending tax audits. He works alongside co-lead David Rosenbloom, a key resource regarding foreign tax credits and subpart F matters, as well as advance pricing agreements. Elizabeth Stevens is an expert in international corporate tax planning, while Kirsten Burmester is noted for advising on offshore investment structures and their US tax implications. In New York, Jonathan S. Brenner advises multinationals and high-net-worth individuals on tax-efficient structures for cross-border transactions.

Practice head(s):

Clark Armitage; David Rosenbloom

Other key lawyers:

Elizabeth Stevens; Jonathan Brenner; Kirsten Burmester

Testimonials

‘Focus on international tax issues from a US perspective.’

‘Always there to help with their expertise.’

Work highlights

  • Advised a consulting business on transitional matters and forward-looking structural planning and implementation, valued at $500m.
  • Advised a Mexican pension fund on the status under the PATH Act of a mixed public/private Mexican pension plan and established structures for it to invest in U.S. real estate and non-real estate assets.
  • Represented a major retailer in obtaining US federal income tax certainty with regard to its foreign garment sourcing operation.

Clifford Chance

Working alongside a network of global offices in 22 countries, the New York-based international tax team at Clifford Chance is particularly strong advising on multi-jurisdictional tax-related transactions, tax risks, and securitizations. Practice head David Moldenhauer is a key resource for tax structuring, private equity investments, and corporate acquisitions and restructurings. He works alongside Avrohom Gelber, a specialist in cross-border finance and CLO securitizations; Philip Wagman, who focuses on domestic and cross-border M&A and leveraged buyouts; and Michael Seaton, an expert in complex REIT transactions and the formation of mortgage-backed securities. Counsel Rebecca Pereira covers tax structuring advice for investment management funds, while James Gouwar is noted for his work on structured finance transactions, including REMICs. Additionally, international tax specialist Paul Seraganian joined from Osler, Hoskin & Harcourt LLP in November 2021.

Practice head(s):

David Moldenhauer

Other key lawyers:

Mike Seaton; Avrohom Gelber; Philip Wagman; Rebecca Pereira; James Gouwar; Paul Seraganian

Testimonials

This team has been incredibly helpful with our review of M&A tax insurance submissions and tax policy underwriting. They’re top specialists in the field and are both very technical and commercial, which makes a difference in the context of M&A transactions especially.

Key clients

Ardian

Aberdeen Standard Investments

Watford Holdings Ltd.

Almanac Realty Investors

Stockbridge Capital Group, LLC

DigitalBridge (f/k/a Colony Capital)

alterDomus

American Landmark

Huntsman Corporation

Capital Dynamics

Ready Capital Corporation

Mercer Alternatives AG

Tikehau Capital North America LLC

Credit Suisse Asset Management, LLC

Cantor Fitzgerald

Work highlights

  • Advised private equity firm Ardian on tax aspects of the strategic acquisition by its investee company, The Dedalus Group, of DXC Technology’s healthcare software provider business.
  • Advised Aberdeen Standard Investments on the tax aspects of the secondary sale of a ~$500m portfolio of over 140 LP positions held across eight vehicles advised by Aberdeen Standard Investments to a new ASI-managed vehicle seeded by Coller Capital’s CIP VIII.
  • Advised Watford on the tax aspects of its approximately $700m sale to Arch Capital Group Ltd.

Dechert LLP

Working in close collaboration with its London, Luxembourg, and Paris offices, Dechert LLP provides tax advice to global asset management firms, financial services firms, and mutual and investment funds. The team is particularly strong in advising middle-market private equity firms on structuring of M&A transactions, holding companies, and financing. Additionally, it deals with tax aspects of structured finance and securitizations, as well as REITs and transfer pricing agreements. In New York, practice head Joshua Milgrim advises private equity firms and public and closely-held companies on corporate transactions, as well as the formation of investment management companies. He works alongside Ari M. Zak, a specialist in international taxation of investment funds. Structured finance transaction experts William Cejudo and Michael Rufkahr are based in Washington DC., while in Boston Adrienne M Baker covers FATCA compliance and tax for private and regulated investment companies. In November 2021, M&A tax specialist David Passey joined from Schulte Roth & Zabel LLP. Daniel M Dunn has retired, while Steven E Clemens departed in June 2021.

Practice head(s):

Joshua Milgrim

Other key lawyers:

Ari Zak; William Cejudo; Michael Rufkahr; Adrienne Baker; David Passey

Key clients

B&G Foods

Harvest Capital Credit

Court Square Capital Partners

Crown Holdings

Fannie Mae

FS/KKR Advisor

GIC

JP Morgan

One Equity Partners

Quest Diagnostics

Work highlights

  • Advised GIC on the merging of the business of benefits administration company Alight Solutions LLC with a special purpose acquisition company, Foley Trasimene Acquisition Corp.
  • Advised J.P. Morgan in connection with the acquisitions of both Campbell Global and OpenInvest, adding to the company’s ESG offerings.
  • Advised GIC as part of an investor group in connection with the $34bn acquisition of a majority stake in medical supply company Medline.

Hogan Lovells US LLP

The international tax team at Hogan Lovells US LLP is linked to a worldwide set of offices in Europe and Latin America. Based in Washington DC, practice leader Siobhan Rausch frequently advises tax-exempt organizations and foreign universities on international tax matters and cross-border grant-making. She works alongside Jasper Howard, who deals with tax-free spin-offs and restructurings; Cristina Arumi, a key resource regarding capital markets transactions and M&A involving REITs; and senior associate Caitlin Piper, an expert in tax-related M&A matters. In San Francisco Josh Scala covers public and private REITs, while in Baltimore Nancy O’Neil focuses on cross-border tax planning. Counsel Jennifer Morgan joined from Winston & Strawn LLP in March 2021 and is noted for her work in private equity and partnership tax. Babak Nikravesh departed in July 2021.

Practice head(s):

Siobhan Rausch

Other key lawyers:

Jasper Howard; Cristina Arumi; Caitlin Piper; Josh Scala; Nancy O’Neil; Jennifer Morgan

Testimonials

‘The Hogan Lovells International tax team is very diligent, responsive and a value-added partner to our global business.’

‘The Hogan Lovells international tax team of Mark Weinstein, Phil Ehrlich, Steven Palyca, and Sophie Beutel, among others have truly understood our global business and have provided first class tax technical support over the years.’

Key clients

Marvell Technology

Arm Limited

Dell Technologies

Transurban

Kingdom Holding

FLIR Systems

WSP Global

Syncreon

Ventas

GP Strategies Corporation

Jefferies International Limited and Panmure Gordon (UK) Limited

Ivanhoé Cambridge

Arcturus UAV

Quadriga Capital

Autodesk

Helsinn

Work highlights

  • Advised Marvell Technology Group on its approximately $9.4bn acquisition of publicly traded Inphi Corp., a high-speed data movement platform.
  • Advised Transurban on its $2.1bn sale of a 50 percent interest in its Transurban Chesapeake assets, which include its Virginia toll roads, to Australian investors AustralianSuper and UniSuper, and the Canada Pension Plan Investment Board.
  • Advised Dell Technologies on the tax elements of its $2.075bn sale of RSA to a consortium of investors led by Symphony Technology Group, Ontario Teachers’ Pension Plan Board, and AlpInvest Partners.

Paul Hastings LLP

Paul Hastings LLP is noted for its international tax work on cross-border M&A, leveraged finance, and private equity. It is particularly strong on REIT work. The New York practice is led by Joseph Opich, a specialist in cross-border tax planning and structuring. He works alongside David Masko, who focuses on cross-border transactions and international business tax planning. In Chicago, Ziemowit Smulkowski deals with cross-border investments and international acquisitions and dispositions, while Orange County-based Douglas Schaaf covers tax advice regarding international business transactions. Chair of the Palo Alto office Thomas Wisialowski advises on venture capital and real estate transactions, including private REITs and real estate funds. Additionally, Lucas Rachuba joined from Ernst & Young LLP in January 2021, and is an expert in the tax aspects of compensation structuring.

Practice head(s):

Joseph Opich

Other key lawyers:

David Masko; Ziemowit Smulkowski; Douglas Schaaf; Thomas Wisialowski; Lucas Rachuba

Testimonials

‘They understand the Latin American space and speak the same language.’

‘Paul Hastings International Tax practice is well resourced, the attorneys are highly competent and always available on short notice and on at almost all hours. Billing is eminently fair. We could not function as well as we do without this group of advisors.’

‘David Makso is our main counterpart at Paul Hastings International Tax. He is highly knowledgeable and a very good explainer. He is patient and positive no matter how basic or complex the questions and problems. He works extremely hard but always acts as the firm’s front man. If he delegates, the associates are invited to participate in meetings and it is obvious that they enjoy working together.’

‘Douglas Schaaf is very easy to get along with, advice is delivered in plain English, to the point. They make the complex simple rather than overselling their services. Its amazing how much we get done in a short thirty minute call.’

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 (“TIAA”)

Saba Software

Subversive Capital L.P.

Francisco Partners

Escalent (a portfolio company of STG Partners)

Endeavour Capital

Sectigo

Work highlights

  • Represented Castle & Cooke in connection with the business combination with Total Produce through an IPO.
  • Advised HYBE on the tax aspects of its cross-border acquisition of Ithaca Holdings.
  • Advised TIAA and its investment manager company, Nuveen Alternatives Advisors, on the formation of an open-ended global farmland fund that will target agricultural investments.

Reed Smith LLP

Reed Smith LLP advises clients in media and entertainment, music publishing, and healthcare on tax matters related to international M&A. Team co-chairs James Tandler and Angelo Ciavarella are based in New York and focus on the tax aspects of international corporate transactions. They work alongside Cheryl Hader, a specialist in estate, gift, and income tax planning for high-net-worth individuals. Based in Washington DC, Jeffrey Korenblatt is an expert in transfer pricing and international tax planning. International tax planning specialist Ron Scharnberg joined from Baker Botts L.L.P. in March 2021, while David Hryck departed in March 2021.

Practice head(s):

James Tandler; Angelo Ciavarella

Other key lawyers:

Jeffrey Korenblatt; Cheryl Hader; Ron Scharnberg

Testimonials

‘We had a complex corporate acquisition to complete under considerable time pressure. The team from Reed Smith were professional, friendly and responsive – I became confident that when I assigned a task to them they ensured it was completed quickly and well – they also ensured I was made aware of their decision making process and their explanations were clear and meaningful.’

Vinson & Elkins LLP

Vinson & Elkins LLP advises clients in the energy, finance, technology, and real estate sectors on tax matters concerning cross-border M&A and public offerings, REITS, and SPACs. In Houston co-department head George Gerachis and recently promoted Dallas-based co-head David Peck both cover cross-border M&A and transfer pricing planning. Operating out of Houston, John Lynch specializes in federal tax aspects of international energy and infrastructure transactions, while in Washington DC Natan Leyva advises multinationals on US tax compliance. She works alongside Gary Huffman, a key resource for international tax planning and litigation. Ron Nardini joined from Akin Gump Strauss Hauer & Feld LLP in June 2021. He is noted for his work on tax aspects of international investment of venture capital and hedge funds.

Practice head(s):

George Gerachis; David Peck

Other key lawyers:

John Lynch; Natan Leyva; Gary Huffman; Ron Nardini

Testimonials

‘Hugh level of expertise. Thoughtful and invested.’

Key clients

DigitalBridge

Hygo Energy Transition

CIIG Merger Corp.

Spartan Acquisition Corp. III

WPT Industrial Real Estate Investment Trust

Switchback Energy Acquisition Corporation

Decarbonization Plus Acquisition Corporation & Decarbonization Plus Acquisition Corporation II

Frank’s International

The Lion Electric Company

Transcanada Pipeline USA, Ltd.

Live Oak Acquisition Corp. II

TPG Pace Beneficial Finance Corp.

Queen’s Gambit Growth Capital

Crestline Investors

Setzer Properties; Jera Partners

The Carlyle Group

First Reserve Sustainable Growth Corp.

Work highlights

  • Advised DigitalBridge in its acquisition of a controlling stake in Vertical Bridge Holdings.
  • Advised The Carlyle Group in a $374m investment commitment to Amp Solar Group, a Canadian-based global renewable energy platform, to support its growth in core markets in North America, Japan, Australia, Spain and the UK.
  • Advised The Lion Electric Company in its $1.9bn business combination with Northern Genesis Acquisition Corp.

BakerHostetler

Based in Washington, DC, Baker & Hostetler LLP advises on tax-related matters related to cross-border transactions, general corporate law, and forensic tax controversies. It is particularly strong dealing with cross-border mergers, joint ventures, and restructurings, as well as taxable presence for corporations and private equity funds. Brian Davis leads the team and covers both complex cross-border tax disputes and transactional work. Jeffrey Paravano deals with tax controversies, investigations, and litigation, cross-border tax planning, as well as REIT and venture capital transactions. Chairman of the firm Paul M. Schmidt is a tax specialist covering transaction structuring and international tax controversies.

Practice head(s):

Brian Davis

Other key lawyers:

Jeffrey Paravano; Paul Schmidt

Key clients

The Sherwin-Williams Company

Progressive Insurance Company

American Resort Development Association

Work highlights

  • Represented a client as lead tax counsel in Moore v. United States, a tax refund action currently pending in the 9th Circuit Court of Appeals.
  • Represented an aerospace manufacturer in its acquisition of Cobham Aero Connectivity.
  • Represented an aerospace manufacturer in its sale of ScioTeq and TREALITY Simulation Visual Systems businesses to OpenGate Capital for approximately $200m.

Cadwalader, Wickersham & Taft LLP

Cadwalader, Wickersham & Taft LLP is particularly strong in cross-border US-UK tax matters related to M&A structuring, international spin-offs, inversions, divestitures, and joint ventures. Its clients include multinational corporations, private equity and investment firms, and investment banks. The team also covers cross-border restructurings, SPACs and de-SPAC work, reorganizations, and developing structuring securitization vehicles. Based in New York, chair of the tax group Linda Swartz specializes in structuring complex cross-border M&A, spin-offs, and restructurings, financial products and SPACs. Jason Schwartz left the firm in February 2022.

Practice head(s):

Linda Swartz

Testimonials

‘While small, CWT has several high performing partners who are expert in their space. I find them extremely strong for securitization, financial products and international tax.’

Key clients

Assured Guaranty Corp. and Assured Guaranty Municipal Corp.

MBIA, Inc.

Pershing Square Tontine Holdings

Kingsland Holdings Limited

Alternative Reference Rates Committee (“ARRC”)

Forbes Global Holdings

Deutsche Bank

Hudson Executive Capital

Investec

Morgan Stanley

Fintech Ecosystem Development Corp.

Work highlights

  • Represented 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.
  • Represented 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,” or, individually, as Zohar I and Zohar II.
  • Represented Kingsland Holdings in the Chapter 11 cases for Avianca Holdings.

Cooley LLP

Cooley LLP provides international corporate tax advice to clients in the technology, life sciences, and media industries. The team’s experience ranges from tax-related matters concerning SPACs, M&A, and disposals to capital markets deals and fund formation. In Los Angeles, Alexander Lee advises on international tax aspects of IPOs, M&A, and disposals, while San Diego-based Todd Gluth focuses on tax work involving M&A in the technology and life sciences sectors. In the New York office Jeffrey Tolin is noted for advising charities and tax exempt organizations on tax matters related to M&A.

Other key lawyers:

Alexander Lee; Todd Gluth; Jeff Tolin

Key clients

Baylis Medical

Canoo

FinAccel

GGV Capital

Horzon Therapeutics

Paidy

Merus NV

Shamrock Capital Advisors LLC

Super Group

Turning Point Therapeutics, Inc.

VelosBio

Vividion Therapeutics

Xos Trucks

Work highlights

  • Advised Shamrock Capital on the tax aspects (including significant partnership tax planning) of the disposal of its stake in Mobilitie LLC to Australian group BAI Communications —backed by Canada Pension Plan Investment Board (CPPIB).
  • Advised Indonesian digital credit platform FinAccel on its merger with VPC Impact Acquisition Holdings II.
  • Advised Super Group, a holding company for leading global online sports betting and gaming businesses Betway and Spin, on its agreement to merge with Sports Entertainment Acquisition Corp.

Curtis, Mallet-Prevost, Colt & Mosle LLP

Curtis, Mallet-Prevost, Colt & Mosle LLP advises on tax matters related to M&A, fund formation, and international tax controversies. Its client base includes financial institutions, investment funds, and sovereign wealth funds. In New York, US chair Klas Holm focuses on cross-border transactions and global tax planning. Also in New York, Olga Beloded advises foreign multinationals and ultra-high-net-worth individuals on tax planning and cross-border transactions. Counsel Beth Kerwin joined from Baker McKenzie in August 2021, and specializes in US tax planning for ultra-high-net-worth individuals, working across the New York and Paris offices. Eduardo Cukier departed the team.

Practice head(s):

Klas Holm

Other key lawyers:

Olga Beloded; Beth Kerwin

Testimonials

‘Excellent knowledge and responsiveness.’

‘Klas Holm has complete tax knowledge and business acumen.’

Key clients

Unipharm

Brevet Capital Management

E.ON SE

Burgan Bank

United Gulf Bank

Work highlights

  • Advised U.S.-based pharmaceutical company, Unipharm, in all ongoing tax matters including cross-border M&A transactions as well as tax planning.  
  • Advised Brevet Capital Management on a broad range of matters relating to transactions, the structuring of investments, and cross-border tax issues.
  • Represented long-standing client E.ON SE on a broad range of matters, including a recent $20bn global restructuring involving asset and business swaps across multiple jurisdictions.

Hughes Hubbard & Reed LLP

Based in New York, Hughes Hubbard & Reed LLP advises on tax-related matters concerning international M&A, spinoffs, and off-shore investment funds. The team has sector-specific expertise in the life sciences, media, and entertainment industries. Practice chair Andrew Braiterman covers tax aspects of M&A, hedge funds, and private equity funds. Alan Kravitz deals with tax matters related to aviation and equipment finance, while Jerry Harrison advises on international tax planning projects. Cross-border M&A tax expert Ruben Diaz was promoted to managing partner of the Miami office in March 2021. Employment tax specialist Charles Wachsstock joined from Arnold & Porter in May 2021.

Practice head(s):

Andrew Braiterman

Other key lawyers:

Alan Kravitz; Jerry Harrison; Ruben Diaz; Charles Wachsstock

Key clients

Grab Holdings, Inc.

William Shu (founder and CEO of Deliveroo)

Wipro Limited

Griffin Global Asset Management LLC and Bain Capital Credit LP

Goldman Sachs

CF Finance Acquisition Corp. V

Blackbird Capital II LLC

United Airlines, Inc.

Delta Air Lines, Inc.

JD Sports Fashion plc

Citigroup Global Markets Inc. and BNP Paribas (as financing parties)

Banco Nacional de Fomento (BNF)

Roku, Inc.

Tao Group Hospitality

Work highlights

  • Advised Grab Holdings Inc. in its $39.6bn proposed merger with Altimeter Growth Corp., a special purpose acquisition company.
  • Advised global information technology company Wipro in its $1.5bn acquisition of British tech consultancy firm Capco.
  • Advised Roku in connection with a deal to acquire Nielsen’s advanced video advertising business.

Miller & Chevalier Chartered

Based in Washington DC, Miller & Chevalier Chartered advises Fortune 500 and Fortune 100 companies on tax matters regarding restructuring, optimization, financing transactions, and corporate M&A. The team also represents clients on international tax controversy relating to foreign tax credits, Subpart F issues, and withholding tax. Kevin Kenworthy specializes in advising multinationals in tax litigation before courts and the IRS, while Layla Asali covers cross-border M&A, IP transactions, and financings. Rocco Femia is noted for his work on international transfer pricing planning and controversy and Loren Ponds focuses on transfer pricing, OECD, and general international tax matters.

Practice head(s):

Kevin Kenworthy; Layla Asali

Other key lawyers:

Rocco Femia; Loren Ponds

Key clients

Semiconductor Industry Association

Freeport McMoRan Inc.

The Coca-Cola Company

Brown Forman Corporation

CVS Health

T-Mobile US, Inc.

HP Inc.

McDonald’s Corporation

Work highlights

  • Representing a financial guaranty insurer to secure legislation to address an unintended consequence of modifications to the passive foreign investment company (PFIC) insurance exception enacted as part of the Tax Cuts and Jobs Act (2017).
  • Advised the Semiconductor Industry Association (SIA), the trade association that represents the U.S. semiconductor industry.

Norton Rose Fulbright

Norton Rose Fulbright advises on international investments and acquisitions, transactions, and reorganizations. The team also represents multinationals on international tax disputes, litigation, and investigations. It has particular strengths advising key industry clients in oil and gas. In Houston, global head of tax Andrius R Kontrimas covers global tax planning, joint ventures, M&A, and transfer pricing.

Practice head(s):

Andrius Kontrimas

Key clients

BMO Financial Group

BlueFocus Communication Group

Ai-Media

Diamond Offshore Drilling, Inc.

Adams Offshore Services (ADAMS)

Noble Corporation plc

Work highlights

  • Advised BMO Financial Group in the $615m sale of its EMEA Asset Management business to Ameriprise, a diversified financial services company.
  • Advised BlueFocus Communication Group on its $350m sale to CVC Capital, CDPQ.
  • Advised Diamond Offshore Drilling, Inc. in US competent authority proceedings related to multiple countries, including Australia, Egypt, Mexico and the United States, as well as refund claims for foreign tax credits.

Sullivan & Worcester LLP

Based in Boston, Sullivan & Worcester LLP provides international tax advice on foreign investment, tax planning and implementation. Its offering includes M&A, dispositions and reorganizations, cross-border financing, foreign tax credits, and US tax deferrals on foreign earnings. Niche expertise includes advising sovereign wealth funds, high-net-worth individuals, and foreign governmental pension plans. Practice head Douglas Stransky focuses on international tax planning for US-based clients investing in foreign jurisdictions. Co-head Ameek Ponda handles tax-related matters arising from corporate M&A and public and private REIT activity. Irina Pisareva departed in August 2021.

Practice head(s):

Douglas Stransky

Other key lawyers:

Ameek Ponda

Testimonials

‘We have worked directly with Douglas Stransky and consider his team very professional and helpful. They have certainly added value to our common client’s situation.’

‘Douglas Stransky has been clear and concise in their analysis and conclusions, always thinking outside the box and giving us some asset structure alternatives which the client always appreciates.’

‘Highly skilled individuals with broad understanding of a broad range of issues that impact multinational companies. Network of international contacts who have always met the challenges we have presented them.’

‘I’ve been working as an Israeli tax expert in collaboration with a few of the partners of the Sullivan & Worcester tax department for a period of 7 years. The International tax practice is unique in understanding both the federal and the internatioanl aspects of cross border transactions that took place between Israeli and US entities, with an emphasis on Israeli high-tech companies. The team I worked with was adapted exceptionally well with the legal frame and cultural differences between Israel and the US.’

‘Doug Stransky is an encyclopedia when it comes to the federal tax system, as well as exceptional knowledge of US DTTs. I worked with Mr. Stransky during the Trump Tax reform and its ramificiations on US investments in Israel, as well as coping with unique circumstances related to US individuals who immigrated to ISrael and are considered dual tax residents of both Israel and the US. Mr. Stransky was a real pleasure to work with. He is always accomodating and free to consult on many federal tax issues.’

Key clients

Broadstone Group, LLC

Halo2Cloud

Iron Mountain Incorporated

Equinix, Inc.

Lionbridge Technologies, Inc.

Altra Industrial Motion

E Ink Corporation

Standex International

DarioHealth Corp.

Work highlights

  • Advised  DarioHealth on its $30m acquisition of PsyInnovations, Inc.
  • Represented the Broadstone Group LLC in connection with the 2021 Summer Olympic Games in Tokyo and the 2028 Summer Olympic Games in Los Angeles.
  • Advised American Tower Corporation, Equinix, Inc., Iron Mountain Incorporated, Industrial Logistics Properties Trust, Office Properties Income Trust, Service Properties Trust, and Diversified Healthcare Trust on tax issues.

Withers LLP

Withers LLP advises ultra-high-net-worth individuals on international tax holdings. Splitting his time between Connecticut and New York, William Kambas focuses on US tax structuring and tax planning. In Los Angeles, Michael Brophy covers trusts and estates litigation, while Charles Kolstad is an expert in digital asset, income, and estate tax planning. Michelle Graham operates out of San Diego and advises ultra-high-net-worth individuals with US assets. 2021 saw the opening of a new Texas office, lead by cross-border tax expert Kevin Keen, who joined in March from Winstead PC. Additionally, Marsha Laine Dungog was appointed San Francisco office leader in February 2021, and specializes in Canadian and Australian tax, trust, and superannuation matters.

Practice head(s):

William Kambas; Michael Brophy

Other key lawyers:

Charles Kolstad; Michelle Graham; Kevin Keen; Marsha Laine Dungog; Bill Kambas

Testimonials

‘When it comes to cross-border international tax planning, especially related to trusts and estates, the folks at Withers Bergman are some of the best around the globe. Whether it is North America, South America, Asia, Europe, or some combination of all those locations, Withers Bergman will be able to assist.’

‘When working on international planning matters, it is important to have some of the most talented and experienced attorneys on your team. But that is not enough. You also want to work with nice people who care about their clients, which is what you will find at Withers Bergman.’

‘A very detailed knowledge of the international tax provisions of the U.S. but also of different foreign jurisdictions and specially how they interact. Withers counts with diverse professionals who were trained and practiced in foreign jurisdictions which gives them an edge on understanding how international tax structures and transactions are regulated in the different jurisdictions involved.’

‘Michelle Graham is extremely thorough in her analysis of transactions and in the advice she provides, while still being able to design and implement business-friendly and practical solutions for very complex cross-border situations. Her understanding of the Mexican legal and tax system is a huge asset that sets her apart from other U.S. practitioners whose knowledge is limited to local laws.’

‘Withers Bergman LLP is an outstanding boutique law firm specializing in all aspects of income and estate taxation, including international taxation. The firm is characterized by outstanding, brilliant attorneys who work as a team to provide outstanding client service.’

‘The team at Withers has a very good combination of strong technical skills and a strong focus on relationships. They work well together and do not hesitate to bring in colleagues that can bring additional expertise to client situations. They are very collaborative.’

‘Bill Kambas has strong technical expertise on cross-border matters and values thought leadership on both strategic legal and regulatory issues.’

Work highlights

  • Advised a successful Bitcoin investor on his contingent residency, tax and wealth planning including advice on international income and transfer tax, residency and immigration issues.
  • Advised a Zurich-based Trust Company on the purchase, financing and leasing of a new made-to-order Gulfstream G500.

Holland & Knight LLP

Holland & Knight LLP‘s practice has grown with the addition of head of the international estate planning group Kevin Packman and tax practice chair William Sherman following its merger with Thompson & Knight in August 2021. Based in Fort Lauderdale, Sherman specializes in international tax advisory and planning work for clients active in telecoms, transportation, and pharmaceuticals industries, amongst others. Packman operates out of Miami and advises high-net-worth individuals on pre-immigration and expatriation planning, as well as tax compliance and controversy matters.

Practice head(s):

Kevin Packman; William Sherman

Key clients

ExxonMobil Corporation

Western Union

Work highlights

  • Represented ExxonMobil in a $1.5bn tax appeal.
  • Represented Western Union before the U.S. Treasury and Congress regarding potential modifications to the global intangible low-taxed income regime (GILTI) and a potential new interest limitation under proposed section 163(n).

Karlin & Peebles

Karlin & Peebles specializes in advising ultra-high-net-worth individuals and European-based start-ups on the intersection of tax, estate planning, and business planning. Based in Los Angeles, Michael Karlin co-leads the practice, focusing primarily on cross-border tax matters such as pre-immigration and expatriation, reporting foreign financial accounts and holdings. He works alongside co-leader Jane Peebles. She focuses on international estate planning and administration. Cynthia Brittain joined from Baker & Hostetler LLP in October 2021, and is a specialist in international corporate tax as well as international wealth and asset transfers.

Practice head(s):

Michael Karlin; Jane Peebles

Other key lawyers:

Cynthia Brittain

Steptoe & Johnson LLP

Based in Washington DC, Steptoe & Johnson LLP acts for major international corporations in the manufacturing, banking, and defense sectors on both contentious and non-contentious international tax issues. Practice co-chair Phil West and Amanda Varma advise multinationals and high-net-worth individuals on tax planning, tax controversies, and competent authority proceedings; co-chair Robert Rizzi specializes on federal tax and SALT aspects for multinationals; and Lisa Zarlenga covers tax policy issues. In New York, co-chair Beth Tractenberg advises high-net-worth individuals on international tax planning. Transfer pricing litigators Steven Dixon and Lawrence Hill joined from Miller & Chevalier Chartered and Winston & Strawn LLP in October and June 2021, respectively. Suzanne McDowell has retired.

Practice head(s):

Phil West; Beth Tractenberg; Robert Rizzi

Other key lawyers:

Amanda Varma; Lisa Zarlenga; Steven Dixon; Lawrence Hill

Key clients

Cross-Refined Coal

Work highlights

  • Represented and provided counsel to a foreign government regarding taxes on digital services and an investigation of the tax by the Office of the United States Trade Representative’s (USTR).
  • Assisted a globalised US business in regard to a competent authority matter concerning a foreign tax adjustment related to an internal business restructuring regarding intellectual property.
  • Advised an energy company on the US foreign tax credit consequences of a foreign government’s changes to the tax payment structure of the client’s joint venture with government-owned enterprises.