The New York-based tax department at Cravath, Swaine & Moore LLP designs tax-efficient structures for an array of US and cross border transactions, including, mergers, spin-offs, joint ventures, private equity fund formations, acquisitions and internal restructurings. Lauren Angelilli heads the practice and focuses on advising clients on the tax and structuring aspects of M&A, joint ventures and SPACs. Ronald Creamer Jr.  regularly counsels clients on the execution and IRS review of tax-efficient financing techniques and capital market strategies. Len Teti possesses expertise in connection with the execution of spin-offs and Christopher Fargo advises on tax issues in M&A transactions. Andrew Davis focuses his practice on private equity transactions as well as securities offerings, while Arvind Ravichandran advises on restructuring transactions and related financings. Stephen Gordon retired as a partner in 2022.

DLA Piper LLP (US) routinely handles tax advisory work on multinational companies’ cross-border integrations and resolves complex jurisdictional issues The practice is well-versed in transfer pricing matters such as international transfer pricing disputes, intercompany transactions, advanced pricing agreements and cross-border supply chain restructuring. The team operates across a range of industries such as technology, industrials and life sciences. Alison Maxwell leads the team out of Seattle and assists clients in legal entity rationalization and intellectual property planning. Sang Kim is based in Silicon Valley and concentrates on operational structuring and joint ventures while New York-located Kevin Glenn works on a broad range of cross-border tax planning issues and opportunities.

Kirkland & Ellis LLP advises on US and foreign tax issues in addition to representing clients in disputes worldwide. On the transactional front, the team advises clients in connection with M&A, acquisitions, buyouts, fund formations and restructurings. The firm is also well-versed in issues relating to investment fund sponsors and the formation of offshore private equity funds, as well as advocating on behalf of companies at every stage of the tax controversy process from pre-audit planning to administrative appeals. Chicago-based Todd Maynes focuses on debt restructurings and co-heads the team with New York-located Dean Shulman who has extensive experience in structuring transactions. Chicago-located Lee Morlock focuses on international tax planning. Sara Zablotney operates out of New York and handles the tax aspects of joint ventures and spin offs while Mike Carew advises on securities issuances with support from Mark Schwed. The team was strengthened in October 2022 with the arrival of David Cole from Vinson & Elkins LLP, who has expertise in disputes in both federal and state courts.

Mayer Brown provides the full range of tax services including transactional, advisory and planning to multinational businesses, financial institutions, funds, trade associations and other clients, advising on all areas of inbound and outbound planning, mergers, acquisitions, divestitures, leveraged and structured financings. The practice is also known for its expertise in transfer pricing providing assistance in large case audit and administrative appeals, US and foreign unilateral and bilateral advance pricing agreements, competent authority matters and litigation. The team is co-led with New York-based practitioners Jason Bazar and Brian Kittle regularly working on cross-border financing transactions and tax controversies respectively. Tom Kittle-Kamp operates out of Chicago and represents clients in every phase of tax controversy and litigation with support from Kenneth Klein.

The team at Debevoise & Plimpton LLP works closely with clients from a range of industries including media, healthcare, insurance, investment management and real estate, as well as investment banks, on complex mergers and acquisitions, spin-offs, international transactions, private equity and hedge fund formations. The practice is headed by Peter Schuur who advises clients on US and cross-border mergers and acquisitions transactions with a focus on corporate deals in the insurance industry. Peter Furci practices extensively in the area of private investment funds including emerging markets while Michael Bolotin focuses on private equity fund formation. Gary Friedman is well-versed in acquisitions and financings. All lawyers are based in New York.

The Washington DC-based international tax group at Eversheds Sutherland regularly advises clients on  inbound and outbound tax consequences of cross-border transactions and investments, encompassing transnational mergers, acquisitions and issues relating to the use of foreign tax credits. The practice handles transfer pricing regulations and their application involving US and non-US based multinationals. Robert Chase co-heads the team and assists clients in restructurings and finance company arrangements. Fellow co-head Mary Monahan focuses particularly on tax accounting and income recognition. Caroline Setliffe represents multinational corporations in domestic and foreign tax controversies while Randy Buchanan has expertise in issues pertaining to joint ventures and treaty considerations.

McDermott Will & Emery LLP represents large Fortune 500 multinational companies in addition to public and private mid-size smaller companies, offering a strong transactional and advisory practice covering large M&A, spin-offs, transfer pricing and corporate restructuring. Additionally, the team regularly advises high-net worth individuals including private clients, their trusts and estates. Tim Shuman  leads the practice, operating out of Washington DC, with expertise in cross-border acquisitions, dispositions, restructurings and liquidations. Damon Lyon and Lowell Yoder, based in Chicago, focus on global planning and international controversies. Also in DC, Caroline Ngo frequently counsels both inbound and outbound clients on a broad range of international tax issues.

The team Paul, Weiss, Rifkind, Wharton & Garrison LLP represents clients in transactional and advisory matters including M&A and private equity deals for large alternative asset managers in the market, and is also well-versed in whole-business securitization transactions, transformational IPOS and out restructuring transactions. Brad Okun co-heads the New York-based practice and is experienced in advising limited liability companies and partnerships as well as cross-border investing. Scott M. Sontag has expertise in the formation and acquisition of REITs while Jeffrey Samuels covers partnership and joint venture transactions. Lindsay Parks regularly counsels investment funds and strategic clients in restructurings.

Proskauer Rose LLP works on the full range of tax issues including advising on cross-border structuring issues, transfer pricing considerations, asset and business migrations, anti-deferral regimes and tax treaty benefits. The New York-based team is particularly well-versed in transactional taxation counsel, providing advice on capital raising and financing transactions in addition to restructuring matters. Amanda Nussbaum heads the practice and is experienced in the structuring of international private investment funds. David Miller covers the taxation of financial instruments and derivatives while Martin Hamilton handles US corporate, partnership and international tax matters. Mary Kuusisto advises clients with respect to their internal governance and economic structures.

Shearman & Sterling LLP is well-regarded for its cross-border tax capabilities with advice provided to a variety of clients from local and global corporates to financial institutions. The team works with investment banking firms and other financial advisors to develop tax-efficient structures for financings, hybrid securities, acquisitions, joint ventures and other investments. Larry Crouch heads the tax team and has extensive transactional experience in matters involving international transactions, M&A, capital markets and joint ventures. Kristen Garry routinely advises on structured finance transactions while Jay Singer focuses on spin-off transactions. Lorenz Haselberger‘s client list includes banks, hedge funds, fintech companies and cryptocurrency custodians. All lawyers are based in New York.

Simpson Thacher & Bartlett LLP offers a renowned capital markets tax practice which advises on initial public offerings and provides solutions to issuers. The practice offers the full spectrum of deal and fund capabilities including financings, capital markets transactions and restructurings. The team also has expertise in providing tax advice relating to real estate investments by fund sponsors. Nancy Mehlman co-heads the practice and advises on fund formations, partnerships and joint ventures. Other co-head Marcy Geller has expertise in REITs and real estate transactions while Jonathan Goldstein provides advice with respect to the Foreign Account Tax Compliance Act. All lawyers are in New York.

The New York-based team at Weil, Gotshal & Manges LLP has cross-border expertise on a range of transactional matters including complex M&A, private equity, recapitalizations, securitizations, REITs and capital markets. The tax team assists in all phases of a restructuring such as modifications of debt, equity exchanges and pre bankruptcy planning. Devon Bodoh heads the practice and advises clients on SPAC IPOs, restructurings, bankruptcy and foreign tax credits. Kimberly Blanchard focuses on business formations and joint ventures while Greg Featherman advises on the use of net operating losses and consolidated return matters.

Operating out of New York, the Allen & Overy LLP team represents a range of clients including governments, financial institutions, corporations, insurance companies, funds and institutions in the investment sector. The team is experienced in advising on corporate joint ventures, mergers and acquisitions, cross-border financings, inbound and outbound investment. Dave Lewis has significant expertise in international tax planning and co-heads the team practice with Jack Heinberg. Caroline Lapidus focuses on the formation and operation of investment funds and carried interest structures.

Baker Botts L.L.P. assists clients with transactional tax issues including project investments, joint ventures, mergers, restructurings and asset leasing. The team is also well-versed in drafting and negotiating tax-related provisions in acquisitions, financing and project agreements. Derek Green  is based in Houston and focuses on federal income tax matters including securities offerings. He co-heads the the practice with Stephen Marcus, operating out of Dallas, who has substantial experience in the real estate and energy sectors.

Caplin & Drysdale, Chartered advises on number of cross-border issues such as proposed regulations, GILTI foreign-tax credit basketing issues and remedies for BEAT exposure. The practice is also experienced in international transfer pricing issues including tax planning advice on compliance with US and foreign rules. Clark Armitage co-heads the team and is routinely involved in defending tax audits and other administrative controversies. Other co-head David Rosenbloom has expertise in advance pricing agreements and individual tax compliance while Jonathan Brenner advises businesses on tax-efficient structures. All lawyers are based in Washington DC.

Clifford Chance's New York-based team provides a range of legal services in relation to international tax such as regularly developing novel tax structures that enable complex REIT transactions to be completed. The team is also experienced in funds and securitization transactions in addition to the creation of mortgage-backed securities. David Moldenhauer heads the practice and regularly advises clients on difficult tax structuring problems relating to investment funds and corporate acquisitions. Philip Wagman focuses on structured finance and securitization transactions while Michael Seaton represents investment managers and funds.

Dechert LLP provides tax advice to a number of different clients including financial services firms, asset managers and investment funds, handling complex structured finance and securitization transactions, alongside advising on tax issues pertaining to issuers and underwriters. The practice has expertise in advising non-US investors investors in using BDC’s as a vehicle to invest in US originated loans. Joshua Milgrim leads the team from New York with particular experience in advising life science companies. Philadelphia’s Edward Lemanowicz concentrates on executing taxable and tax-free transactions.

Dentons advises clients ranging from individuals to large multinational groups on matters involving multiple jurisdictions. On the outbound investment front the firm aids clients with structuring foreign operations to avoid controlled foreign corporation, as well as being well-versed in inbound investment and helps clients to navigate US income tax exposure and minimize risk. The team is led by John Harrington in New York, who has extensive experience in dealing with foreign tax credit and international tax legislative matters. Mark Astling is based in Salt Lake City and focuses his practice on corporate and pass-through entities and individuals.

Hogan Lovells US LLP operates across several industry sectors with particular strength in private capital, life sciences, healthcare, logistics, media and entertainment. The firm offers full service transfer pricing capabilities including tax-efficient supply chain management, tax valuations and financial modelling. Siobhan Rausch leads the practice and focuses on the area of tax-exempt organizations, advising charitable, educational and health institutions. Cristina Arumi advises a number of REITs on compliance with tax protection agreements while Jasper Howard assists with both domestic and international joint ventures. Caitlin Piper works on joint ventures, spin-offs and reorganizations.

Vinson & Elkins LLP has a diverse client base which encompasses public and private corporations, private equity funds and investors. The team is particularly well-versed in taxation matters across areas such as energy, partnerships, real estate investment trusts and SPACs. The practice has expertise in international tax planning issues including formations of new financing structures, transfer pricing and restructurings. Dallas-based David Peck is experienced in advising companies on tax planning and structuring transactions. He co-leads the team with Ryan Carney  in Houston who represents issuers and underwriters in IPOs. Also in Houston, George Gerachis heads the firm’s tax controversy practice and resolves IRS audits and appeals for clients.

The international tax team at BakerHostetler assists clients with a range of matters including structuring inbound and outbound business and real estate investments, cross-border mergers, spin-offs and restructurings. The practice also handles forensic tax controversies before the IRS and transfer pricing matters. Brian Davis heads the team, with experience in tax reform and global debt issues, while Paul Schmidt handles tax controversies. Lawyers mentioned are in Washington DC.

Cadwalader, Wickersham & Taft LLP‘s expertise encompasses bankruptcy tax matters, ERISA and REMICA issues, restructuring of foreign debt and new money investments by foreign entities. The firm’s clients include multinational corporations, special purpose acquisition companies and investment firms. Linda Swartz heads the New York-based practice and advises clients on fund structures, financings and derivative transactions in addition to foreign tax planning strategies.

The New York-based department at Curtis, Mallet-Prevost, Colt & Mosle LLP represents US and non-US based clients on a broad range of matters including joint ventures, restructurings, fund formation and financing transactions. The team is also experienced in representing foreign sovereigns and sovereign wealth funds in connection with international arbitrations. Marco Blanco is a disputes expert and co-heads the practice with tax controversy specialist Klas Holm. Olga Beloded is well-versed on international tax issues in the oil & gas sector.

Holland & Knight LLP handles all aspects of federal, state and foreign tax planning in addition to structuring, compliance, audits and litigation. Miami's Kevin Packman co-leads the team and handles trusts and estates matters for high-net worth private clients. Other co-heads William Sharp, based between Atlanta and San Francisco, and Florida-based William Sherman focus on tax controversy and restructuring matters respectively.

Hughes Hubbard & Reed LLP provides transactional expertise in several areas of law including international mergers and acquisitions, spinoffs, joint ventures, bankruptcies, reorganizations, equipment and aviation finance. Andrew Braiterman leads the team and represents clients on international tax planning and issues relating to debt restructuring. Spencer Harrison counsels on disputes with federal and state taxing authorities in addition to tax planning projects. Lawyers mentioned are in New York.

Miller & Chevalier Chartered provides international tax advice at every stage of the business cycle of cross-border operations from acquisition and restructuring to termination and dispositions. The practice handles financing transactions. licenses and technology transfers. Marc Gerson focuses on focuses on federal tax policy matters and co-heads the team with Layla Asali who is experienced in representing clients before the Treasury on regulatory matters. Lawyers mentioned are in Washington DC.

Withers LLP is noted for its expertise in traditional private wealth law particularly among multigenerational high-net worth families. The practice is co-headed by New York's William Kambas , who focuses primarily on international tax planning with emphasis on tax structuring for US and non-US business owners and investors. The other co-heads are Jason Dinwoodie in Connecticut and Michael Brophy  in Los Angeles, both experienced in risk assessment and counseling.

Morrison Foerster handles tax matters related to sovereign investors, wealth funds, public sector pension plans and other state-owned institutions. The firm has experience in advising both issuer and large financial institution clients on a broad range of capital market transactions, derivatives and financial instruments. New York-based practice head Anthony Carbone focuses on tax planning strategies for business, investment and capital market transactions. Babak Nikravesh left for Greenberg Traurig LLP in September 2023.