International tax in United States

Cleary Gottlieb Steen & Hamilton

Cleary Gottlieb Steen & Hamilton advises multinational clients, financial institutions, investment funds, governments, and individuals on the full range of international tax matters including mergers, acquisitions, joint ventures, start-ups, and cross-border direct investments. Practice head Meyer Fedida regularly supports clients with the tax aspects of complex multijurisdictional M&A, private equity deals, as well as fund formation matters. Jason Factor focuses on domestic and international tax aspects related to private equity and hedge funds, partnership and joint venture arrangements, divestitures, private clients’ tax work, real estate, and financing transactions. William McRae has a special focus on taxation of non-US sovereign wealth funds as well as international tax planning for multinational corporate groups, among other specific tax issues. Leslie Samuels‘ practice covers all aspects of international and domestic taxation, including mergers and acquisitions, new financial products and foreign direct investment in the US. Diana Wollman has expertise in international tax controversy issues and complex M&A. Susanna Parker supports clients with tax issues relating to private equity and hedge funds whilst Maureen Linch, who is based in the Bay Area, focuses on advisory tax matters that affect both domestic and international businesses. All lawyers mentioned are in New York unless otherwise stated.

Practice head(s):

Meyer Fedida


Key clients

Stripe, Inc.


Alphabet


Warburg Pincus


Mubadala Investment Company PJSC


TPG


T-Mobile US, Inc


Vale S.A.


Genesis Global Holdco, LLC


Thales


Sixth Street


Viking Global Investors LP


Financière Pinault


Institute of International Bankers


Fomento Económico Mexicano S.A.B. de C.V. (FEMSA)


Tempur Sealy International Inc.


Advent International Corporation and Warburg Pincus


Cravath, Swaine & Moore LLP

Cravath, Swaine & Moore LLP’s New York-based tax team designs tax-efficient structures for a broad range of US and cross-border transactions, including mergers, spin-offs, joint ventures, private equity fund formations, and internal restructurings. Practice head Lauren Angelilli focuses on advising clients on the tax and structuring aspects of M&A, joint ventures, and spin-offs. Alongside advising on the tax aspects of M&A, Ronald Creamer advises clients on the IRS review and execution of tax-efficient financing techniques. Christopher Fargo advises on transactions across a wide range of industries, such as media and entertainment, consumer products, retail, and energy. Leonard Teti has extensive expertise advising companies on the tax issues arising out of complex, cross-border M&A and spin-off transactions as well as advising clients during audits by the IRS and other tax authorities. Andrew Davis has a special focus on the tax aspects of M&A, including SPAC, spin-offs, and private equity transactions. As well as advising on M&A, Arvind Ravichandran also advises clients on strategic alliances, restructuring transactions and related financing, and private equity investments across multiple asset classes.

Practice head(s):

Lauren Angelilli


Key clients

AngloGold Ashanti


Bacardi


Brookfield Renewable


Deutsche Börse


Micro Focus


Newcrest


Novartis


Rothschild


Route Mobile


RWE


SMBC Aviation Capital


WiseTech


Work highlights


  • Represented Novartis, as U.S. tax counsel, in connection with the $11.4 billion spin-off of Sandoz.
  • Advised Newcrest Mining in connection with its A$28.8 billion acquisition by Newmont.
  • Advised Bacardi in connection with its acquisition of ILEGAL Mezcal and its long-term agreement with Shawn “JAY-Z” Carter to renew their partnership with D’USSÉ.

Davis Polk & Wardwell LLP

The tax team at Davis Polk & Wardwell LLP, headed by David Schnabel, provides tax advice for complex US and international transactions, including acquisitions, disposals, internal reorganizations, and joint ventures. The team also has a strong tax controversy practice supporting clients in high-stakes tax litigation, investigations, and audits before the state and federal courts as well as the IRS. Schnabel, alongside providing tax advice on M&A and financings, has deep expertise in partnership investments and corporate transactions. Neil Barr offers a wide-ranging commercial practice advising companies, senior executives, and boards on the tax aspects of US and cross-border transactions. Lucy Farr and Michael Farber have a special focus on US and international tax planning for financial institutions. Michael Mollerus has expertise advising U.S. and international corporate, real estate and private equity fund clients on the tax aspects of initiate public offerings and spinoffs as well as other major transactions. William Curran, Patrick Sigmon, and Ethan Goldman have a special focus on federal income tax aspects of domestic and international transactions. Corey Goodman and Kara Mungovan support clients with tax aspects of major cross-border transactions including M&A, bank financings, and capital markets transactions. All lawyers mentioned are in New York.

Practice head(s):

David Schnabel


DLA Piper LLP (US)

DLA Piper LLP (US)’s ‘extremely knowledgeable and approachable’ tax practice, headed by Seattle-based Alison Maxwell and New York-based Maruti Narayan , advises clients active in various sectors, such as technology, industrials, and life sciences, on the full spectrum of international tax related matters including tax planning, transactional, and controversy services. Maxwell has a special focus on advising on the structuring of large-scale, international integration and acquisition transactions whilst Narayan has considerable expertise in US tax policy matters, including supporting clients with proposed tax reform provisions and advising on the impacts of OECD provisions on global taxation. Sang Kim, based in Palo Alto, handles a wide range of international tax matters such as global transfer pricing strategy, cross-border M&A, post-acquisition integration, and international tax controversy. New York-based Kevin Glenn has notable experience advising large multinational clients on a broad range of cross-border tax planning issues. Christopher Feldman, who is based in Seattle, assists a wide range of clients from Silicon Valley start-ups to large multinationals on efficient tax structuring. In Boston, the team benefits from Ryan Starr’s global tax and operational business structuring, cross-border M&A, and post-acquisition integration expertise. New York-based Frank Mugabi is considered a multi-disciplinary tax practitioner who splits his practice between international tax planning and transactional tax, including advising on tax aspects of public cross-border M&A transactions. The team welcomed New York's David Pope from Baker McKenzie LLP in February 2023 and Brian Hamano in Los Angeles from Gibson, Dunn & Crutcher LLP  in July 2023. At the associate level, Marc Anthony Casale in New York and LA-based Tuan Quang Ngo are notable team members.

Practice head(s):

Alison Maxwell; Maruti Narayan


Testimonials

‘Responsive, driven, deeply technical yet practical. The diverse range of talent within the partner team brings together a unique blend of skills and specialties which translates into a tremendous advantage for the firm’s clients. ’

‘Maruti Narayan is exceptionally knowledgeable on a wide range of tax advisory and planning matters. Her people skills make her a tremendous asset to both the firm and her clients as she helps teams navigate complex projects with ease.

‘Frank Mugabi’s technical expertise stands out in every meeting he’s in. He is able to break down intricate webs of interconnected rules into coherent, practical answers to most complex questions.’

‘Alison Maxwell has great knowledge of our pending matters and our company. She combines technical knowledge with the ability to translate it into pragmatic advice. Tuan Ngo is the associate who keeps all of our pending matters on the table, ensures follow up and maximizes his own network within the firm to ensure appropriate expertise is pulled in and the involved colleagues are up to speed on what needs to be done.’

‘Extremely knowledgeable and approachable team with broad technical skills across numerous industries and topics. Top partners are very accessible and engaged rather than delegating work to more junior attorneys.’

‘The combination of deep technical knowledge, extensive experience and brass-tacks practical advice is what sets DLA Piper apart. Some advisors can tend to skew towards either the technical or the practical – DLA consistently brings them both together. Kevin Glenn and Maruti Narayan stand out in this area and are trusted advisors for us.’

‘Ryan Starr is always there for me. Not wedded to overly technical answers. He is very practical.’

‘The geographic reach of the DLA tax practice is rare and valuable. We often have large complex cross-border transactions and DLA Piper is uniquely situated to provide critical advice regarding far-flung jurisdictions, with an experienced team in the US (where we are headquartered) to tie everything together and deliver a cohesive quality work product.’

Key clients

Warner Bros. Discovery, Inc.


Veralto (Danaher Spinoff)


Genpact


Bloomberg


Crocs, Inc.


International Flavors & Fragrances, Inc.


MKS Instruments, Inc.


Herbalife Nutrition Ltd.


Juniper Networks, Inc.


Danaher Corporation


Coupa Software, Inc.


Conair LLC


Yamaha Corporation


Sarepta Therapeutics


iTeos Therapeutics


NVIDIA Corporation


Moody’s Corporation


FibroGen, Inc.


Yahoo!, Inc.


Xilinx, Inc.


Snowflake Inc.


Insmed, Inc.


Sony


Ford Motor Company


Pfizer Inc.


Macquarie Holdings (USA)


Veralto


Centroid Investment Partners LC / Taylor Made Golf


Work highlights


  • Advised Warner Brothers Discovery, Inc. (WBD) on a massive internal restructuring engagement.
  • Advised MKS Instruments on the acquisition and post-acquisition structuring of the complex and significant US$6.5 billion acquisition of Atotech Ltd.
  • Advised Masimo on the international tax implications related to its acquisition of Sound United, a US$1 billion consumer technology company, including worldwide tax due diligence assessments.

Kirkland & Ellis LLP

Kirkland & Ellis LLP advises on tax planning in connection with domestic and foreign M&A, buyouts, fund formations, restructurings, bankruptcy reorganizations, financings, and executive compensation arrangements. Practice head Dean Shulman, who is based in New York, has significant experience advising on and structuring transactions, including partnership workouts and restructurings, like-kind exchanges, and transactions involving the formation and operation of partnerships. In Chicago, Rachel Cantor‘s practice is focused on the tax aspects of complex business transactions, with particular experience handling private equity, LBO, and merger and acquisition transactions. New York-based Sara Zablotney advises on the full spectrum of transactions, including M&A, divestitures, joint ventures, and spin-offs. In Chicago, Mike Carew has expertise in the tax aspects of M&A, buyouts, and private equity investing and Lee Morlock advises Fortune 500 and Global 500 companies on the structuring of cross-border operations. In New York, Mark Schwed supports public companies and private equity sponsors and their portfolio companies on their domestic and international acquisitions, investments, divestitures, joint ventures, financings, and restructurings. Restructuring transaction specialist Anthony Sexton and Polina Liberman are both based in Chicago, and Adam Kool, who handle the full breadth of business transactions, practices from New York. In 2023, the team welcomed the expertise of David Foster from Skadden, Arps, Slate, Meagher & Flom LLP and Sam Kamyans from Allen & Overy LLP, both based in Washington DC.

Practice head(s):

Dean Shulman


Other key lawyers:

Rachel Cantor; Sara Zablotney; Mike Carew; Lee Morlock; Mark Schwed; Anthony Sexton; Polina Liberman; Adam Kool


Key clients

AE Industrial Partners


Alpine Investors


Bain Capital


BC Partners


Blackstone


BlockFi Inc.


Blue Owl Capital


Brookfield Asset Management


Cineworld Group plc


Energy Capital Partners


Fortress Investment Group (Senior Management)


GTCR


I Squared Capital (ISQ)


Sycamore Partners


TA Associates


THL


Thoma Bravo


Veritas Capital


ZC Group


Mayer Brown

The team at Mayer Brown advises multinational companies and private equity clients on aspects of the full lifecycle of their multi-jurisdictional transactions, including M&A, divestures, fund formations, partnerships, and capital market transactions. The team works extensively with clients to comply with global tax reform, namely BEPS and reporting requirements. The team is headed by New York-based Jason Bazar , Brian Kittle , Lucas Giardelli , Chicago-based Thomas Kittle-Kamp, and Washington DC-based Jason Osborn . Giardelli’s practice covers international tax planning for US and non-US multinational companies and corporate tax matters, advising clients on the tax aspects of acquisitions, divestitures, financing arrangements and other transactions. Osborn has extensive experience in international tax and transfer pricing planning, specifically focusing on IP planning and tax efficient restructurings. Bazar handles the tax aspects of cross-border and domestic financing transactions, and Kittle and Kittle-Kamp are both tax controversy and litigation specialists. In Washington DC, Kenneth Klein advises clients on structuring and restructuring of multinational corporations in multiple industries, such as software, agricultural, manufacturing, and financial trading, while Gary Wilcox has significant experience with federal tax controversies arising from complex cross-border transactions. Chicago's Jenny Austin supports clients through all stages of tax controversies, from IRS audits to administrative appeals, alternative dispute resolution proceedings, and litigation. Sonal Majmudar joined the Washington DC team in 2023 from the IRS.

Practice head(s):

Jason Bazar; Brian Kittle; Thomas Kittle-Kamp; Benjamin Homo; Lucas Giardelli; Jason Osborn; Guido Vinci


Testimonials

‘Technical very strong yet still pragmatic.’

‘Lucas Giardelli: extremely good at C-suite explanation of highly complex restructuring matters.’

 

Key clients

American Express


Assured Guaranty


Caisse de Depot et Placement du Quebec (CDPQ)


Canadian Imperial Bank of Commerce (CIBC)


Ferrara Candy Company


ENGIE


Eaton Corporation


Gerber Products Company


HSBC


Nestlé S.A.


Sumitomo Mitsui Banking Corporation (SMBC)


TC Energy


Work highlights


  • Advised ENGIE Brasil on the acquisition of Atlas Energia Renovável do Brasil S.A. and Atlas Brasil Energia Holding 2 S.A.
  • Advising The Halifax Group on its agreement to acquire the Worldwide Home Care division of Sodexo (France), including their home care subsidiaries in the US, UK, Ireland, France, Denmark, Norway, Sweden and Brazil.
  • Representing Ferrara Candy Company in connection with its acquisition of Dori Alimentos.

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP‘s international tax group advises on the full range of international tax matters from transactional tax planning for acquisitions, joint ventures, and restructurings, to transfer pricing and controversy matters. Washington DC-based Eric Sensenbrenner, who has a special focus on transactional tax planning, leads the team. Nathan Giesselman, who sits in the Palo Alto office, advises clients on a wide range of internal and third-party transactions, including acquisition, disposition, and restructuring transactions. In Boston, Moshe Spinowitz handles both transactional tax planning for multinational companies and tax controversy matters throughout the full lifecycle of IRS audits and appeals. Gavin White, who is based in New York, has extensive experience advising on the tax aspects of public and private acquisitions, divestitures, bankruptcy reorganizations, equity and debt offerings, and joint ventures. Also in New York, Victor Hollender supports a wide range of clients with their tax issues such as publicly traded corporations, financial institutions, fund managers, foreign pension funds, and sovereign wealth funds whilst Chase Wink has significant experience handling a broad range of international tax matters including subpart F, global intangible low taxed income (or GILTI), foreign tax credits, documentation concerning transfer pricing rules and the tax aspects of operational integration. In Washington DC, David Farhat‘s practice focuses on all phases of international tax planning and dispute resolution whilst Nathaniel Carden supports with complex transfer pricing issues.

Practice head(s):

Eric Sensenbrenner


Weil, Gotshal & Manges LLP

Weil, Gotshal & Manges LLP offers tax-efficient solutions to US and non-US investors active in a wide range of transactions including private equity and private funds matters, restructurings and recapitalizations, securitizations, REITs, capital markets, and M&A. The team has particular strengths in the bankruptcy tax space, routinely advising on the full lifecycle of a restructuring including modification of debt, tax planning for liquidation, and employment tax liabilities. The global tax group routinely collaborates with the private funds group often advising new entrants to the funds and private equity market on tax related matters. Splitting his time between the Washington DC and Miami office, Devon Bodoh heads the practice which includes New York-based Greg Featherman. Both Bodoh and Featherman have extensive expertise advising clients on cross-border mergers, acquisitions, spinoffs and other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, and other tax attributes and consolidated return matters. In New York, 'excellent professional' Helyn Goldstein is also a key team member.


Practice head(s):

Devon Bodoh


Other key lawyers:

Greg Featherman; Helyn Goldstein


Testimonials

‘The tax team is top notch, delivering in all fronts in the tax space. They were incredible at weeding through the legal elements to achieve my business objectives.’

‘Helyn S. Goldstein is an excellent professional with a wealth of experience in all kinds of tax matters. She’s a good communicator and has the ability to navigate the technical tax issues in all of our business transactions.’

 

Key clients

Advent International


Aman Group S.a.r.l.


British Columbia Investment Management Corporation


Brookfield


CPP Investments


Eli Lilly and Company


Glencore plc


Hayfin Capital Management


Intermediate Capital Group


JPMorgan Chase


Ontario Teachers’ Pension Plan


Providence Equity Partners


PSP Investments


Sanofi S.A.


Work highlights


  • Advising Glencore PLC, Canada Pension Plan Investment Board and British Columbia Investment Management Corporation, as the shareholders of Viterra Ltd on the tax aspects of its approximately $18 billion business combination with Bunge Ltd.
  • Advised Brookfield Asset Management Inc on the tax aspects of the spin-off of a 25% interest in its asset management business through a newly listed company, Brookfield Asset Management Ltd.
  • Advised CPP Investments, together with Silver Lake, on the tax aspects of its acquisition of Qualtrics.

Shearman & Sterling LLP

A&O Shearman offers a strong global tax practice, regularly providing clients with international strategic tax planning advice and representation in a variety of complex transactions as well as tax controversy and cross-border restructuring matters. The team has notable strengths in Chinese tax matters. Team lead Larry Crouch has significant experience advising on the tax aspects of various international transactions including mergers and acquisitions, capital markets and joint ventures. Crouch has particular expertise in transactions involving private equity sellers and buyers. Jay Singer advises clients on tax aspects of corporate transactions, particularly domestic and cross-border mergers and acquisitions, tax-free spin-offs and internal restructurings. Ryan Bray’s practice covers tax planning for domestic and cross-border M&A transactions and advising clients with respect to all corporate tax matters. Bray regularly advises emerging growth companies and their founders in connection with choice-of-entity decisions, including qualified small business stock planning. At the associate level, Matthew Brown supports clients on a wide range of domestic and international tax planning and transactional matters. All lawyers mentioned are in New York. Following the merger with Allen & Overy, the team has expanded. New York-based Dave Lewis, who has vast experience in tax planning for corporate mergers and acquisitions, private equity transactions, domestic and international joint ventures and global capital markets transactions, and Jack Heinberg, whose practice covers international tax planning, the taxation of financial instruments and derivatives, cross-border financing, CLOs, securitizations and other structured finance transactions. In Silicon Valley, Caroline Lapidus focuses her practice on focused on private capital, where she routinely advises sponsors on the formation and operation of investment funds and carried interest structuring as well as their portfolio investments. John Hibbard, who sits in the New York office, advises on a wide range of tax issues, such as M&A, taxation of capital markets transactions including securitizations, financial instruments and derivatives, cross-border financing transactions, project finance and FATCA.


Practice head(s):

Larry Crouch


Other key lawyers:

Jay Singer; Ryan Bray; Matthew Brown; Dave Lewis; Jack Heinberg; Caroline Lapidus; John Hibbard


Key clients

ADNOC Logistics & Services plc


Amyris, Inc.


Azul S.A.


Boston Scientific Corporation


Celanese Corporation


Paramount Global


EMG Fund V SVRE Holdings, LLC


Investcorp Europe Acquisition Corp I


J.F. Lehman & Company LLC


Liberty Global


Mubadala Investment Company


SAP SE


Vision Blue Resources Limited


Worldwide Webb Acquisition Corp.


Glatfelter Corporation


Work highlights


  • Advised SAP SE in connection with the pending sale of Nasdaq-listed Qualtrics International Inc to Silver Lake Management and the Canada Pension Plan Investment Board.
  • Advised Brazilian airline Azul S.A. and its subsidiaries in connection with a comprehensive restructuring plan to significantly strengthen its capital structure and improve its cash generation.
  • Advised Boston Scientific Corporation in its definitive agreement to acquire Baylis Medical Company for a purchase price of $1.75 billion.

Baker McKenzie LLP

Drawing upon its international platform, Baker McKenzie LLP advises multinational companies on the full spectrum of international tax planning matters including multijurisdictional supply chain, M&A, IP company, post-acquisition integration, and restructuring. The team also supports on tax policy, tax disputes, and transfer pricing issues. The tax team is co-led by Washington DC-based Salim Rahim, Reza Nader, who sits in the New York office, and Julia Skubis Weber, who is based in Chicago. Nader routinely advises clients on tax structuring for global transactions, regularly as part of dispositions, acquisitions, or legal entity rationalization projects. Weber supports multinational and foreign-owned clients on cross-border tax issues, including internal reorganizations, structuring of outbound and inbound investments, foreign tax credits, subpart F, PFICs, withholding and treaty analysis. In Palo Alto, Stewart Lipeles advises US-based multinational corporations in connection with international tax planning and global tax projects. Also in Palo Alto, Sibel Owji‘s practice is focused on corporate international tax, global transfer pricing strategy and documentation, and international tax controversy whilst Robin Chesler focuses on international tax planning for US multinationals. Los Angeles-based Ethan Kroll has significant experience handling US international income taxation matters. In Miami, Robert Moore advises on tax planning for US and foreign-based multinational corporations and partnerships focused on luxury hotel, residences, and resorts, real estate development, and consumer goods and retail in luxury and fashion.

Practice head(s):

Salim Rahim; Reza Nader; Julia Skubis Weber


Testimonials

‘Baker McKenzie’s International Tax Team has great experience, and they have a vast network which helps address a variety of tax matters.’

‘Baker McKenzie’s International Tax Partner, Sibel Owji has both breadth and depth. She’s versed in the technical matters and considers all the variables (not just the specific issue at hand). Additionally, she understands the balance of technical requirements vs. practical approach.’

 

Key clients

Wilbur-Ellis


Cummins Inc.


Thomson Reuters


Whirlpool Corporation


Work highlights


  • Represented Wilbur-Ellis in a combination of Wilbur-Ellis’ Connell business with Caldic B.V., a portfolio company of Advent International, in a cash and stock transaction.
  • Represented Cummins Inc. in connection with the restructuring, realignment and eventual IPO of its filtration business unit, which is now held by Atmus Filtration Technology Inc (“Atmus”), currently a majority owned subsidiary of Cummins.

Debevoise & Plimpton LLP

Debevoise & Plimpton LLP‘s New York-based team represents a wide variety of clients including investment banks in complex mergers and acquisitions, spin-offs, international transactions, private equity, and hedge fund formations, among other international taxation issues. The team is headed by Peter Schuur, who has extensive expertise in US and cross-border M&A, joint ventures, and spin-offs, with a focus on corporate transactions in the insurance industry, as well as advising clients on the structuring and formation of private investment funds and international investment platforms. Peter Furci ’s practice covers the full range of international taxation matters, including private investment funds, such as emerging markets, hedge, mezzanine, distressed debt, infrastructure, and real estate funds. Michael Bolotin advises US and foreign clients on M&A real estate joint ventures, the formation of real estate investment trusts, equipment finance and private investment fund formation. Erin Cleary supports private equity and corporate clients in a broad range of M&A transactions and advises sponsors on the formation of US and international private equity funds. Stephen Jordan represents private equity and investment management firms on a full range of international transactional and advisory matters and Rafael Kariyev advises clients on tax structuring of acquisitions, holding and disposition of portfolio companies, both pass-throughs and corporations, as well as transactions involving the restructuring and sale of existing funds and asset managers. Daniel Priest and Lena Smith are also key team members.


Practice head(s):

Peter Schuur


Testimonials

‘Incredible expertise in insurance and specifically offshore reinsurance, sidecars, etc.’

 

Key clients

Brookfield


TPG


Prosperity Life Group


INDICOR


Fortitude Re


Morgan Stanley Capital Partners


The Dolan Family


Spirit Airlines


SiriusXM


Swiss Re


Providence Equity Partners


Kelso & Company


Ascent Global Logistics


Pernod Ricard


KKR


Global Atlantic Financial Group


Work highlights


  • Advising Brookfield Reinsurance in its acquisition of American Equity Investment Life Holding Company in a transaction valued at approximately $4.3 billion.
  • Advised TPG in its acquisition of a majority interest in OneOncology, a network of leading oncology practices, in a transaction valued at $2.1 billion.
  • Advised Clayton, Dubilier & Rice and TPG Capital in their acquisition of all outstanding shares of Covetrus, representing an enterprise value of approximately $4 billion.

Eversheds Sutherland

Eversheds Sutherland‘s tax team, headed by Washington DC-based Robert Chase and Mary Monahan, draws on its global network to advise clients on a wide range of international tax related matters. Chase supports multinational companies with the tax-efficient planning of joint ventures, restructurings, dispositions, acquisitions, and finance company arrangements whilst Monahan has extensive experience litigating complex federal tax issues as well as international tax planning for corporate transactions. Also in Washington DC, Randy Buchanan routinely supports multinational corporations on federal and international tax matters with global implications, which includes OECD developments, operational and supply chain planning, transfer pricing, and transactional work whilst Caroline Setliffe has significant expertise advising on domestic and foreign tax controversies, specifically focused on treaty considerations and transfer pricing issues. New York-based Bruce Wright has a special focus on the insurance industry, regularly counselling companies on a wide range of international tax issues such as formation of commercial offshore privately and publicly held entities and Saren Goldner focuses her practice on international tax, insurance, captive insurance companies and insurance tax issues, including structuring operations, investor tax issues in US and non-US insurance companies, and insurance characterization. Clifford Muller, who sits in the Washington DC office, advises global corporations on their complex business transactions, developing tax-efficient structures and ensuring compliance with federal tax law. Also located in Washington DC, Karl Zeswitz supports clients with corporate and partnership tax planning, tax accounting methods, FIN 48 reporting, worker classifications, financing transactions and consolidated return matters. Washington DC-based Xenia Garofalo and Aaron Payne as well as Atlanta-based Wes Sheumaker advise on federal income tax matters. David Fischer, who is based in Washington DC, represents clients in international tax controversy and litigation with federal and state tax authorities. Michael Lebovitz and Megan Hall joined the San Francisco and Washington DC offices in August and February 2023 from Mayer Brown.

Practice head(s):

Robert Chase; Mary Monahan


Key clients

Splitit Payments


NextEnergy Capital


Blue Source Sustainable Forests Company


Vitol


Work highlights


  • Advising Splitit in conjunction with delisting of Splitit from the Australian stock exchange, redomiciliation of Splitit to the Cayman Islands and a US$50 million fresh investment by private equity firm Motive Partners in Splitit.
  • Advising NextEnergy Capital on the launch of its NextPower V ESG fund.
  • Advising Blue Source Sustainable Forests Company in a private forest carbon investment.

Freshfields Bruckhaus Deringer LLP

Freshfields Bruckhaus Deringer LLP advises on a wide range of transactions, including M&A, joint ventures, carve-out transactions, and other capital market transactions. The team is headed by Washington DC-based Claude Stansbury, who advises domestic and foreign multinational companies, private equity funds, and financial advisors on acquisitions, financings, restructurings, and disposals. In New York, Joe Soltis‘ practice covers taxable and tax-free mergers and acquisitions, recapitalizations, financing arrangements, investments, partnerships and joint ventures, bankruptcy reorganizations, securities issuances, and real estate matters. Also in New York, Dennis Caracristi advises on M&A, public and private offerings of stock, debt and other financial products, spinoffs and demergers, structured derivatives, complex securitization transactions, conventional and synthetic financings, and specialized tax advisory and structuring matters.

Practice head(s):

Claude Stansbury


Other key lawyers:

Joe Soltis; Dennis Caracristi


Testimonials

‘Great to work with. Very fair and professional.’

‘Dedication, reliability, and technical expertise.’

 

Key clients

Schenck Process Group, a Blackstone Capital Partners portfolio company


Roivant Sciences Ltd.


Holcim Group Services Ltd


Ericsson


bp


Siemens


Stagwell Media


Pearson plc


Coupa Software Incorporated


London Stock Exchange Group plc


Zymergen


Morgan Stanley


Lilium N.V.


Solvay


Aristocrat Leisure


Scottish & Southern Energy Plc (SSE)


Mercedes-Benz Group AG


Oracle


AstraZeneca PLC


ServiceNow


TriNet


Cinven


CVC Capital


Japan Tobacco


Sonoco


Novartis


One Equity Partners


McDermott Will & Emery LLP

McDermott Will & Emery LLP ‘excels in navigating complex global tax landscapes for multinational corporations’, supporting with M&A, private equity buyouts, and IPO transactions as well as handling complex transfer pricing matters and guiding clients through domestic and global tax policy developments. Practice head Timothy Shuman, who sits in the Washington DC office, has significant expertise handling corporate and international tax matters for acquisitions, dispositions, and restructurings. Also in Washington DC, Michael Wilder supports clients with a wide range of transactional tax matters and routinely represents clients seeking private letter rulings from the IRS and in audit and appeal matters and Caroline Ngo has a special focus on tax planning and structuring work for multinational corporations but regularly litigates in the US tax court. David Noren advises on outbound and inbound tax issues, with a focus on subpart F rules, bilateral income tax treaties, and transfer pricing. In Chicago, Jeffery Maydew advises on business taxation, particularly domestic and international tax planning for mergers, acquisitions, spin-offs and other major corporate transactions and Lowell Yoder assists with tax-beneficial planning for intangible holding companies, global supply chains and multi-jurisdictional service arrangements. New York-based John Lutz has a strong practice in the financial sector, advising major banks on the taxation of sophisticated financial transactions and products such as municipal derivatives, tax-exempt bond securitizations and tax equity structures to fund renewable energy developments. In San Francisco, Dominika Korytek is experienced in developing tax strategies for international expansion, domestic and international acquisitions, reorganizations and dispositions and post-acquisition restructurings. Miami-based Steven Hadjilogiou represents Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects. Manuel Rajunov has left the firm.

Practice head(s):

Timothy Shuman


Other key lawyers:

Michael Wilder; Caroline Ngo; David Noren; Jeffery Maydew; Lowell Yoder; John Lutz; Dominika Korytek; Steven Hadjilogiou


Testimonials

‘Manuel Rajunov’s and Dominika Korytek’s teams are very dynamic and knowledgeable with cross-border transactions.’

‘McDermott Will & Emery’s international tax team excels in navigating complex global tax landscapes for multinational corporations. Their strengths lie in deep expertise, industry-specific knowledge, and tailored strategies. What sets them apart is their innovative use of technology, diverse perspectives, and flexible billing models. They prioritize client collaboration, delivering comprehensive international tax solutions that stand out in the industry.’

‘Steven Hadjilogiou stands out due to his deep expertise in international tax law. His unique insights and strategic approach set him apart from competitors. His qualities, like innovative problem-solving, client dedication, and industry knowledge, contribute significantly to our comment client’s success.’

‘The team is very experienced and has a very collaborative approach. They think out of the box and provide alternatives that accommodate to our client’s needs.’

‘Their responsiveness and experience. The team members are on top of matters and respond swiftly to clients’ needs and questions and have been exposed to so many different cases they can provide great advice and anticipate potential scenarios.’

‘Their experience and cross border work allows them to provide true advice understanding how things work in the different jurisdiction in which thy work, along with their language capabilities.’

Key clients

JAB


Credit Suisse


Monumental Sports and Entertainment


Destillers Group


Ermenegildo Zegna


Irving Oil


Aon


Illinois Tool Works


PGA Tour


Work highlights


  • Advising Credit Suisse on post-acquisition tax integration arising out of the merger Credit Suisse and UBS.
  • Represented Monumental Sports & Entertainment in connection with a minority investment by the Qatar Investment Authority.
  • Advice to Destillers United Group on the tax aspects of the sale of its Diplomático Rum brand to Brown-Forman.

Paul Hastings LLP

Paul Hastings LLP has expertise in complex tax issues including capital markets, M&A, financial structuring, securitization, and private equity. The team is headed by New York’s Joseph Opich whose practice covers the planning, structuring, and transactional federal, state, and cross-border tax law aspects of structured finance, private and public investment funds, and real estate, among other areas. David Makso, who has expertise in tax aspects of highly complex leveraged finance transactions, and Gary Silber, whose practice focuses on domestic and international tax matters relating to bankruptcies, taxable and tax-free M&A, as well as capital market offerings, are key members of the New York team. In California, Douglas Schaaf has broad experience in advising private equity funds on acquisition and disposition tax structuring matters whilst Michael Haun has experience providing tax advice with respect to partnership and limited liability company formation, crypto-currency, and tax-incentivized investments involving low-income housing tax credits. Also in California, Thomas Wisialowski provides tax advice with respect to structuring of major corporate venture capital and real estate transactions, and Lucas Rachuba concentrates his practice on private equity, credit, hedge funds, venture capital and real estate transactions. Ziemowit Smulkowski, who is located in Illinois, has considerable expertise in federal income tax issues related to all private equity-backed investments, management compensation, and M&A. The Chicago team welcomed the expertise of fund tax specialist Paul Patrow who joined the firm from Kirkland & Ellis LLP in April 2023.

Practice head(s):

Joseph Opich


Key clients

Francisco Partners


Scilex Holding Company


SD Biosensor and SJL Partners


Ad Hoc Group of Output Services Group (“OSG”) First Lien Lenders


Symphony Technology Group


FTX


CVC Credit


REEF Technologies


Structured Products Groups at Morgan Stanley, Bank of America/Merrill Lynch, JP Morgan, Credit Suisse, Neuberger Berman, Golub, AGL, Pinebridge, Natixis


Jaguar Global Growth Corporation I


vLex


JS Global


Work highlights


  • Represented Francisco Partners and TPG on the tax aspects of the take-private of New Relic.
  • Represents Korean companies SD Biosensor and SJL Partners on the tax aspect of the US$1.53 billion acquisition of Meridian Bioscience, Inc.
  • Represented the Official Committee of Unsecured Creditors of FTX and its 100+ affiliates that have filed for chapter 11 protection in the United States Bankruptcy Court for the District of Delaware.

Paul, Weiss, Rifkind, Wharton & Garrison LLP

Paul, Weiss, Rifkind, Wharton & Garrison LLP advises Fortune 100 companies, investment firms and financial institutions on a broad range of transactions, including public company M&A, private equity deals for alternative asset managers, SPAC and whole-business securitization transactions, transformational IPOs, and out-of-court and in-court restructuring transactions. The practice is co-headed by Jeffrey Samuels, Brad Okun, Scott Sontag, and Lindsay Parks. Samuels has significant experience advising on tax aspects of public and private M&A, spin-offs, the organization of and structuring of transactions for investment funds, and partnership and joint venture transactions. Okun focuses his practice on the tax law aspects of mergers and acquisitions, restructurings and corporate finance and has experience advising limited liability companies and partnerships, as well as cross-border investing. Sontag regularly structures and negotiates complex merger and acquisition and restructuring transactions for public companies and private equity funds and their portfolio companies. Parks routinely supports investment funds and strategic clients in the negotiation and structuring of a broad range of international and domestic transactions. Robert Holo and Matthew Jordan both advise on federal tax law aspects of domestic and international transactions, including all types of mergers, acquisitions, tax-free reorganizations and spin-offs; cross-border tax matters; joint ventures; and capital markets and financing transactions. Brian Grieve has extensive experience advising alternative asset managers on tax matters related to the formation and operation of both US. and non-US investment funds, including private equity funds, credit funds, hybrid capital/special situations funds, real estate funds, and infrastructure funds, and the structuring of all types of investments by those funds. Robert Killip advises clients on US tax aspects of complex cross-border transactions, internal restructurings, tax-free reorganizations, spin-offs and bankruptcy and insolvency restructurings. The team sits in the New York office.


Practice head(s):

Jeffrey Samuels; Brad Okun; Scott Sontag; Lindsay Parks


Proskauer Rose LLP

Proskauer Rose LLP advises on cross-border structuring issues such as withholding tax, permanent establishment risk, transfer pricing consideration, asset and business migrations, anti-deferral regimes, and tax treaty benefit. Team lead Amanda Nussbaum, who sits in the New York office, has significant expertise in structuring tax free and taxable mergers and acquisitions as well as taxation in the sports industry. Also located in New York, David Miller has considerable experience handling matters relating to the taxation of financial products, lending transactions, M&A, hedge funds, and HNWI, in both a domestic and international context whilst Martin Hamilton advises on cross-border investments and structured financing arrangements, and tax-efficient corporate financing techniques. In Los Angeles, Robert Friedman’s practice covers tax advice on public and private mergers, acquisitions, joint ventures, divestitures, private equity fund formation, financial products, and electric and gas utility tax issues. In Boston, Stephen Severo represents corporate, private equity and investment fund clients in connection with all tax-related aspects of their businesses. At the associate level, New York-based Kathleen Semanski and Washington DC-based Yomarie Habenicht, who both advise on a wide range of cross-border transactions, and Boston-based Philip Lenertz, who has particular strengths in the funds space, are notable team members.

Practice head(s):

Amanda Nussbaum


Other key lawyers:

David Miller; Martin Hamilton; Robert Friedman; Stephen Severo; Kathleen Semanski; Yomarie Habenicht; Philip Lenertz


Testimonials

‘Very focused approach with highly skilled background.’

 

Key clients

abrdn Inc.


Adams Street Partners


Alexandria Real Estate Equities


AllianceBernstein


AnaCap Financial Partners


Apollo Global Management


Ares Management


Atalaya Capital


Blackstone Strategic Partners


BTG Pactual


DataBank / Digital Bridge Advisors


Diabolical Fun / Iron Galaxy Studios


Energy Impact Partners


Grifols


Hollyport Capital


Hoteles City Express, S.A.B. de C.V.


Investcorp


Jaime Gilinski


KKR


Pantheon Ventures


Patria Investments


StepStone Group


Temasek


The Women’s Tennis Association (“The WTA”) and the ATP Tour (“ATP”)


17Capital


7Ridge


Work highlights


  • Advised the Women’s Tennis Association (WTA) in a strategic partnership with CVC Capital Partners (CVC).
  • Advised Patria Investments in its definitive agreement to sell its portfolio company ODATA, a data center service provider offering scalable, reliable and flexible IT infrastructure in Latin America, to Aligned Data Centers.
  • Advised Hollyport Capital on the formation of its latest fund, Hollyport Secondary Opportunities Fund VIII2, which closed above its target of $1.5 billion.

Simpson Thacher & Bartlett LLP

Simpson Thacher & Bartlett LLP advises banks, multinational corporations, investment funds, and other sophisticated businesses active in various industry sectors, including energy, video gaming, telecommunications, and transportation, on the tax aspects of complex transactions including M&A, banking, capital markets, private funds, and real estate. The New York-based team is co-headed by Nancy Mehlman, who has considerable expertise advising on high-profile M&A including tax-free spin-offs, partnerships, and fund formations, and Marcy Geller, whose broad practice covers tax advice for REIT, joint ventures, and corporate restructurings. Jonathan Goldstein advises clients on tax matters regarding financial institutions, renewable energy transactions, and private investment fund formation, among other transactions. Russell Light advises on the tax aspects of M&A, private equity investments and fund formation matters, debt restructurings, and credit investments. Drew Purcell advises on the full spectrum of tax matters including financing, credit, and spin-offs. Sophie Staples advises clients on tax matters in a variety of transactions, including M&A, dispositions, joint ventures, financing transactions, and securities offerings. Benjamin Rippeon supports corporations, investment funds, sovereign wealth funds, joint ventures, partnerships, limited liability companies and special purpose acquisition companies with tax issues relating to complex, cross-border transactions.

Practice head(s):

Nancy Mehlman; Marcy Geller


Testimonials

‘STB’s tax team is one if not the best I have worked with. They are able to work through very complex structures and issues. They work very well with clients, investors and parties on the other side. They are very innovative and solution oriented, while being conservative at the same time. They are always up to speed on current tax law changes and many times have been involved with the process.’

‘Marcy Geller is our main tax contact at STB. She is fantastic. She is extremely intelligent, has amazing tax knowledge and a pleasure to work with. She has the ability to explain complex tax issues to non-tax persons like me. The best tax attorney I have ever worked with and believe me I have worked with many over my career.’

 

Key clients

Apollo Global Management


BlackRock


Blackstone


Bridgepoint Group


Braskem


Carlyle


COPEC


DigitalBridge


Global Infrastructure Partners


KKR


Microsoft Corporation


Monex Group


Silver Lake


Stonepeak Infrastructure Partners


The Toronto-Dominion Bank


Work highlights


  • Representating of affiliates of DigitalBridge Group, Inc. and IFM Investors in connection with their acquisition of Switch, Inc. (“Switch”) in a transaction valued at $11 billion.
  • Representating of CVC in the establishment of its ninth buyout fund, CVC Capital Partners IX (“Fund IX”).
  • Representation of TD Bank Group in its acquisition of Cowen Inc. in an all-cash transaction valued at $1.3 billion.

Wachtell, Lipton, Rosen & Katz

Based in New York, Wachtell, Lipton, Rosen & Katz is known for advising high profile clients on the tax aspects of corporate transactions, including mergers and acquisitions, spin-offs and other divestitures, joint ventures, financings and financial instruments, and restructurings. Jodi Schwartz focuses on the tax aspects of corporate transactions, including mergers and acquisitions, joint ventures, spin-offs and financial instruments. Deborah Paul routinely advises on tax aspects of domestic and cross-border transactions, including strategic acquisitions and private equity buyouts. Eiko Stange has advises on transactions in a wide spectrum of industries including TMT, pharmaceuticals, banking and finance, retail, and real estate. Joshua Holmes concentrates his practice on the tax aspects of M&A, joint ventures, spin-offs and financial instruments. Tijana Dvornic and Rachel Reisberg focus on the tax aspects of M&A and other dispositions, leveraged buyouts, joint ventures and financing transactions.

Key clients

Adobe


Special Transaction Committee of the Board of DISH Network


PENN Entertainment


Capri Holdings


Regency Centers


Michael Jordan


Pfizer


LKQ/Uni-Select


Rockefeller Capital Management


American International Group


RTX


Stratasys Ltd.


Regeneron Pharmaceuticals


FIS


Global Payments Inc.


Apollo


MDU


Sealed Air


Public Storage


Nasdaq


An affiliate of Cigna


Stone Point Capital, Warburg Pincus, Reverence Capital Partners, Sixth Street and Bayview Asset Management


BakerHostetler

BakerHostetler‘s primarily Washington DC-based team supports clients with a broad range of tax matters including cross-border mergers, spin-offs and redomiciliations, joint-ventures, restructuring, the creation of centralized cash management and global hedging centers, implementing sophisticated multi-party hedging transactions, and structuring inbound and outbound business and real estate investments. The team also has particular strengths devising and implementing specialized planning involving transfer pricing such as supply-chain relocations, nearshoring transactions, and contract or toll manufacturing arrangements as well as representing clients before the US Treasury’s Office of Tax Policy and before the IRS. Practice head Brian Davis concentrates his practice on representing clients seeking to optimize global supply chains or establish efficient nearshoring operations and is extremely knowledgeable in respect matters pertaining to transfer pricing, permanent establishments, tax and investment treaties and global tax operating model strategies. Paul Schmidt advises on technical and policy issues in connection with tax reform, transfer pricing, treaties, permanent establishments, US trade and business, subpart F, foreign tax credits, GILTI, FDII, BEAT, inversions, and global debt and hedging issues. Jeffrey Paravano advises on tax issues and structuring of acquisitions, dispositions, tax planning, and disputes as well as being experienced in handling tax controversies and litigation, M&A work, and tax investigations. Federal tax specialist John R. Lehrer II focuses his practice on one-off business acquisition and disposition transactions. Nicholas Mowbray advises clients active in the private equity, technology, energy, agriculture, blockchain and manufacturing sectors on achieving tax efficiency of their commercial transactions. Peter J. Roskam, who heads the federal policy team, supports the tax team in assisting clients in respect of US tax policy matters and its provision of tax-related legislative and regulatory services. Criminal tax expert Carlos F. Ortiz , who sits in the New York office, supports the international tax team with ongoing DOJ and IRS civil or criminal investigations in respect of cross-border tax matters.

Practice head(s):

Brian Davis


Work highlights


  • Representing in Moore v. United States, a tax refund action currently pending at the United States Supreme Court.

Baker Botts L.L.P.

Baker Botts L.L.P. has expertise in all facets of federal income tax considerations facing both foreign and domestic corporations, routinely providing clients with tax advice in connection with M&A and capital market transactions. The firm has a notably strong energy tax practice often structuring and solving complex tax issues for upstream oil and gain transactions, midstream transactions, MLP, LNG projects, and electric transmission and distribution projects. The tax team is co-headed by Steve Marcus and Derek Green. Green advises international oil and gas companies, oil field services companies, and offshore drilling companies on US federal income tax matters in relation to cross-border transactions, mergers and acquisitions, and international joint ventures. Jon Lobb provides tax planning advice to clients in connection with cross-border investments and transactions, including intercompany restructurings and domestic and international energy projects. Katie McEvilly’s practice focuses on tax-efficient structures for domestic and international M&A, joint ventures, separations, restructurings, and other reorganizations.

Practice head(s):

Steve Marcus; Derek Green


Other key lawyers:

Jon Lobb; Katie McEvilly


Key clients

Transocean Ltd.


Liberty Latin America


Hoegh LNG Partners, LP


Seadrill Ltd.


BP America Inc.


Work highlights


  • Advised Seadrill Limited in the $958 million acquisition of Aquadrill LLC.
  • Advised Liberty Latin America Ltd. and América Móvil S.A.B. de C.V on an agreement to combine their respective Chilean operations, VTR and Claro Chile, to form a 50/50 joint venture.
  • Advised Transocean in the $486 million buyout of a Joint Venture formed to acquire Deepwater Drillship.

Cadwalader, Wickersham & Taft LLP

Cadwalader, Wickersham & Taft LLP is known for its work on tax-free and tax-efficient M&A structures, which have been utilized by clients in public, domestic and international mergers and acquisitions, spin-offs, inversions, Reverse Morris Trusts, divestitures and joint ventures. The team also has substantial experience designing tax-efficient restructurings and reorganizations involving troubled and insolvent corporations and other entities with a focus on preserving net operating losses and other tax attributes, whether in or outside of bankruptcy. The practice is headed by New York-based Linda Swartz has significant expertise structuring complex global mergers and acquisitions, spin-offs, joint ventures, and restructurings, and on foreign tax planning strategies. Swartz also routinely advises clients on fund structures, financings and derivative transactions. Jon Brose represents investment funds, including hedge funds, funds of funds, and private equity funds, and their managers on all aspects of their businesses, including management entity and fund formation, seeding arrangements, mergers and acquisitions, partnership tax issues, international tax issues, compensation arrangements, and ongoing investment activities and transactions. Also in New York, Gary Silverstein represents issuers, underwriters, insurers and other parties in connection with the tax aspects of mortgage-backed and asset-backed securities, REMICs, CLOs, CRE-CLOs and other debt issuances. Mark Howe, who sits in the New York and Washington DC offices, concentrates his practice on the tax structuring of domestic and offshore investment funds and in the development, structuring, and implementation of a wide variety of financial and derivative products and transactions, such as fixed income, currency, equity, and commodity linked swaps, forwards, notes, options, and similar instruments and transactions, securities and other instruments with embedded derivatives, and hybrid and synthetic products. Andrew Carlon, who joined the New York office in January 2023 from Cravath, Swaine & Moore LLP, advises clients on the tax aspects of mergers and acquisitions and other corporate transactions such as private company acquisitions and dispositions, joint ventures, taxable and tax-free public company transactions, cross-border restructurings, and spin-offs.

Practice head(s):

Linda Swartz


Key clients

Aegon Asset Management


Alternative Reference Rates Committee and Numerous Global Banks


Assured Guaranty Corp. and Assured Guaranty Municipal Corp.


Barings


Citibank


Cybereason Inc.


Integrated Whale Media Investments


Nearwater Capital


U.S. Bank


Work highlights


  • Advising Hong-Kong based Integrated Whale Media Investments in its pending sale of majority ownership in Forbes Global Media Holdings (“Forbes”) to an investor group.
  • Representing Assured Guaranty Corp. and Assured Guaranty Municipal Corp. (“Assured”) in connection with the Commonwealth of Puerto Rico’s restructuring of approximately $73 billion of outstanding bond debt.

Clifford Chance

Clifford Chance’s New York-based team is well-placed to advise on international tax issues, regularly leveraging on its global nexus to support companies with cross-border tax issues related to their business and financial transactions. Recently promoted to practice head in April 2023, Paul Seraganian has significant experience advising on inbound and outbound tax planning considerations, including treaty-based planning, international joint ventures, permanent establishment considerations, and the development of innovative cross-border structures. Philip Wagman concentrates his practice on the tax aspects of M&A, joint ventures, leveraged buyouts, structured finance, and securitization transactions. Michael Seaton has extensive expertise handling transactions that involve public and private REITs, investment funds, investment structuring, and insurance and reinsurance companies. Avrohom Gelber advises on cross-border finance and capital markets transactions, including complex CLO securitization transactions as well as international financial and business transactions, including the formation of investment funds, corporate acquisitions and restructurings, and derivative financial instruments. Jim Gouwar has substantial experience advising on the tax aspects of structured finance transactions such as mortgage- and asset-backed transactions, collateralized loan and debt obligations, and REMICs. Rebecca Pereira provides advice for a wide range of international transactions, with a particular focus on private equity and real estate funds. Hannah Richard advises clients on the U.S. federal tax aspects of a variety of domestic and international matters. David Moldenhauer retired in April 2023.


Practice head(s):

Paul Seraganian


Key clients

OGCI Climate Investments, LLP


InformaJohn Swire & Sons Ltd.


Admiral Group plc


Grenergy Renovables


Czechoslovak Group (CSG)


Work highlights


  • Advised OGCI CI on its inaugural US$1.5 billion Decarbonization Fund focused on energy transition investments.
  • Advised Informa on its acquisition of Winsight.
  • Advised John Swire & Sons Ltd in its acquisition of Swire Coca-Cola U.S.

Curtis, Mallet-Prevost, Colt & Mosle LLP

Curtis, Mallet-Prevost, Colt & Mosle LLP, co-headed by Marco Blanco and Klas Holm, represents US and international clients on a broad range of matters including M&A transactions, joint ventures, restructurings, fund formation and investments, sovereign wealth fund representation, and financing transactions across several industry sectors including energy, pharmaceuticals, mining, and financial services. The team utilizes the skills of its multilingual group when handling cross-border matters. Blanco, who splits his time between Paris, Geneva, and New York, has significant experience advising including fund investment managers, sovereign wealth funds, and family offices in a vast range of US and international tax matters, including corporate mergers and acquisitions, reorganizations, joint ventures, and capital market offerings. Holm represents corporations, partnerships, trusts, sovereign wealth funds and other pooled investment funds, and individuals in complex tax matters relating to mergers and acquisitions, cross-border transactions, financial instruments and global tax planning and has experience defending clients in tax controversies with the IRS.  Olga Beloded  routinely advises governments and state-owned entities on international tax issues in investor-state arbitration proceedings and other international disputes, particularly in the area of oil and gas. Lea Verdy, who is US and French dual qualified, has played an active role in the drafting and analysis of OECD and UN tax documentation. Lawyers are in New York unless otherwise stated.

Practice head(s):

Marco Blanco; Klas Holm


Other key lawyers:

Olga Beloded; Lea Verdy


Key clients

Brevet Capital Management


Burgan Bank


Evonik


E.ON SE


CrowdStreet Advisors, LLC


Unipharm


Turken House


Libyan Investment Authority (L.I.A.)


Work highlights


  • Advising Brevet on a broad range of transactions and other matters relating to investments, fund and corporate structure, and management of their tax position in general.
  • Advised Burgan Bank in connection with the acquisition of multiple portfolios of U.S. private, venture capital and hedge funds.
  • Advising Evonik Industries AG on a broad range of tax matters, including the implementation and impact of the new Corporate Alternative Minimum Tax.

Dentons

Dentons advises companies on the tax aspect of cross-border issues, including the acquisition and disposition of foreign entities, joint ventures with foreign partners, project financings, privatizations, restructuring of foreign operations, cross-border finance strategies and tax treaty interpretation. The team also advises both US and non-US citizens on both domestic and international tax rules. Practice head John Harrington, based in Washington DC, advises clients on inbound and outbound transactional and compliance issues, international tax legislative, regulatory and treaty matters; and foreign tax credit matters, with subpart F and cross-border activities of companies and individuals. New York-based Rich Williams has considerable experience in a wide range of federal income tax matters, including domestic and international M&A and dispositions, public and private financing, and strategic tax planning. San Francisco-based Linda Pfatteicher’s practice covers international corporate tax and operational structuring, including global expansion, global transfer pricing strategy, supply chain restructurings, intangible property planning, cross-border M&A, post-acquisition integration, and tax controversies. Frank Marano handles corporate, partnership, and business tax planning whilst Mark Astling has expertise in federal tax issues.

Practice head(s):

John Harrington


Key clients

Meopta Group


Starton Therapeutics Inc.


Pen-Link


The Tustin Group, LLC and Aireko Services and Installations, LLC.


MarketStar Holdings, LLC


Quintevents International, LLC


Work highlights


  • Represented the owners of Meopta, a Czech optics maker company, in connection with the sale of the company to Carlyle Group, a US private equity firm.
  • Advised Pen-Link, a portfolio company of private equity firm Spire Capital, in connection with Cobwebs Technologies LTD, in a transaction valued at approximately $250 million.

Hogan Lovells US LLP

Alongside its transactional tax practice, Hogan Lovells US LLP also has standout capabilities in transfer pricing matters, including tax-efficient supply chain management, tax valuations, financial modelling, and transfer pricing compliance and disputes including transfer pricing reports. The firm operates across all industry sectors, but has a special focus on TMT, manufacturing and industrials, and life sciences and health care. The department is led by Siobhan Rausch , who sits in the Washington DC office. Also in Washington DC, Cristina Arumi focuses her practice on the tax aspects of capital markets and M&A transactions involving REITs, real estate funds, joint ventures, and foreign investment in U.S. real estate whilst Jasper Howard advises on mergers and acquisitions of both public companies and closely held businesses in taxable and tax-free transactions, including multistep tax-free reorganizations, domestic and international joint ventures, the structuring of inbound and outbound investments, and other cross-border transactions. In New York, Jessica Millett has significant expertise in the U.S. tax issues that arise in complex real estate transactions including Qualified Opportunity Fund structures, private equity investments, joint ventures, and other investment structures involving tax partnerships, and Mark Weinstein has considerable experience structuring and negotiating tax-efficient strategies for business sales, cross-border joint ventures, and fund investments. Baltimore-based Nancy O’Neil  concentrates her practice on tax planning, working extensively for global clients in the hospitality, investment fund, and financial services industries focused on the US, Europe, and the Middle East. In Washington DC, Caitlin Piper concentrates her practice on the tax consequences of M&A and reorganizations, including where a real estate investment trust is a party. Elizabeth Adams advises on inbound and outbound tax-planning considerations. Christine Lane left the firm in April 2023. In November 2023, Jeffrey Uffner and Steven Schneider both joined from Stroock & Stroock & Lavan LLP whilst Jennifer Morgan departed the firm.

Practice head(s):

Siobhan Rausch


Key clients

Intel


Pantheon Ventures


ASSA ABLOY AB


Shaftesbury PLC


Orthofix Medical Inc.


HDI International/Talanx Group


Marsh McLennan


Pavlov Media, Inc.


Tetra Tech


Equifax Inc.


Stahl


Work highlights


  • Advised Intel Corporation in its agreement to sell an approximately 20% stake in its Austria-based IMS Nanofabrication GmbH business (“IMS”) to private equity investor Bain Capital’s special situations unit.
  • Represented Pantheon in its capacity as a lead investor in the private credit transaction that formed part of Wells Fargo’s sale of approximately US$2 billion of investments in certain private credit and private equity funds managed by Norwest Equity Partners and Norwest Mezzanine Partners.
  • Advised ASSA ABLOY on its US$4.3bn acquisition of Spectrum Brands’ Hardware and Home Improvement division (HHI) and the related US$800m divestment of Emtek and its Smart Residential business in the United States and Canada to Fortune Brands.

Holland & Knight LLP

Holland & Knight LLP advises multinational corporations, HNWIs, family offices, entrepreneurs, foundations, and other private clients in domestic and cross-border tax matters including tax matters involving estate planning, family businesses, fiduciaries, trustees, and charitable giving. The practice is co led by Miami-based Kevin Packman, Stewart Kasner, William Sherman, and William Sharp, who splits his time between the Atlanta, Tampa and San Francisco offices. Packman concentrates his practice on advising US and domestic high-net-worth private clients on tax and trusts and estates matters. Kasner advises ultra-high-net-worth foreign and domestic clients on US federal income, gift and estate tax matters associated with their cross-border investments, including U.S. real estate investments and business activities, as well as pre-immigration tax planning. Sherman provides sophisticated tax planning for M&A, restructurings, joint ventures and investments for clients in diverse industries, including hospitality, petrochemicals, aluminum, tobacco, real estate, transportation, telecoms, retailing, investment management, pharmaceuticals and numerous others. Sharp advises US-based and foreign-based companies, as well as high-net-worth individuals and family offices (both US and non-US based family offices), on domestic and international tax controversy as well as cross border tax planning matters.  Joshua David Odintz, who is based in Washington DC, supports clients with obtaining changes in tax reform bills and FATCA regulations and focuses his practice on tax controversy and withholding tax matters. In Dallas, Mary McNulty has extensive experience litigating cross-border matters.

 

Practice head(s):

Kevin Packman; Stewart Kasner; William Sharp; William Sherman


Other key lawyers:

Joshua David Odintz; Mary McNulty


 


Testimonials

‘Excellent lawyers always on top of the file.’

‘H&K’s team of professionals is highly experienced in working with Latin American jurisdictions. They maintain a very fast and efficient level of service.’

‘Stewart Kasner, senior partner of H&K, with long experience in relations with other countries, especially Latin America. Extensive background in US Tax Law. Sean Tevel, senior partner of H&K, is a young lawyer, very dynamic and with a high level of analysis. Ansell Fernandez, is very dynamic.’

‘Holland and Knight have helped us with tax strategies both domestically and internationally. In addition, they supported us during an extensive and extraordinarily complicated audit by the IRS. ’

‘Mark Melton and others are best in class with respect to tax. The issues we encounter are very complex and don’t have many precedents so understanding and deploying strategies based on intent are quite common.’

‘We use Holland and Knight extensively primarily for Tax related work. They have helped us with tax strategies both domestically and internationally. In addition, they supported us during an extensive and extraordinarily complicated audit by the IRS.’

‘Kevin Packman provides very clear and timely advice in complex trust and estate matters with international US tax issues. He is one of the best US tax lawyers we deal with.’

‘Bill Sharp is a great tax lawyer who is very knowledgeable and great with clients. He has formed a great team and is always introducing other team members.’

Key clients

Takeda Pharmaceuticals USA


Aon


Western Union


Confidential company


Work highlights


  • Advise Takeda Pharmaceuticals USA on tax policy matters.
  • Representing Aon before Congress and the Treasury Department regarding the Build Back Better and Inflation Reduction acts.
  • Represented Western Union, a multinational financial services company, before the Organization of Economic Cooperation and Development (OECD), Working Party 10.

Hughes Hubbard & Reed LLP

Hughes Hubbard & Reed LLP provides advice on a wide range of complex tax issues including national and international mergers and acquisitions, spinoffs, joint ventures, bankruptcies, reorganizations, placement of offshore investment funds, securitizations, and securities offerings, including IPOs. The New York-based team has particular strengths in equipment and aviation finance, among other industry sectors such as life sciences, media and entertainment, and technology. Practice head, praised as a ‘towering intellectAndrew Braiterman represents clients on international tax planning, tax issues relating to debt restructuring, voluntary disclosures by individuals of offshore accounts, and disputes with federal and state taxing authorities. Spencer Harrison has a special focus on the tax aspects of domestic and international M&A, joint ventures, and corporate finance. Alan Kravitz advises assists companies and funds with tax matters relating to the acquisition and disposition of subsidiaries and portfolio companies with a particular focus on the media and technology, telecoms, transport, and logistics sectors. Charles Wachsstock has expertise in executive compensation and employee benefits as well as tax matters in corporate transactions, employment and separation agreements, and compensation programs for public and private companies, financial sponsors, directors, and executives.


Practice head(s):

Andrew Braiterman


Testimonials

‘It is a close-knit, energetic, collaborative team.’

‘Andy Braiterman is a brilliant, deeply experienced, creative international tax lawyer. He is a unique figure, combining towering intellect with a rare degree of pragmatic insight.’

 

Key clients

Cantor Fitzgerald


CI&T


Madison Square Garden Entertainment Corp.


Griffin Global Asset Management; Bain Capital; Arajet


Griffin Global Asset Management


Stanadyne LLC and Pure Power Technologies Inc.


Wipro


Griffin Global Asset Management, Palisade Aviation Holdings Warehouse, Ltd. and Palisade Aviation Holdings Warehouse, LLC


JOST Werke


Work highlights


  • Advised F Acquisition Corp. VI in its $2.1 billion merger with Rumble Inc. that took the Canadian neutral video platform public.
  • Advised Madison Square Garden Entertainment Corp. and TAO Group Hospitality in the $550 million sale of TAO Group Hospitality to global investment company Mohari Hospitality.

Vinson & Elkins LLP

Vinson & Elkins LLP advises on the tax aspects of complex transactions for US and non-US businesses raising equity and debt capital, buying, selling, or reorganizing businesses, and entering into joint ventures. The firm has particular expertise in the areas of traditional and renewable energy, partnerships including MLPs, REITs, SPACs, and Up-C structures. The team is co-headed by Dallas-based David Peck and Houston-based Ryan Carney who both advise on the full spectrum of transactions including M&A, fund formations, and investments. In Washington DC, Gary Huffman advises major multinational corporations, including large banks and oil and gas exploration and production companies, on inbound and outbound cross-border transactions. In Dallas, Natan Leyva has significant experience handling the cross-border transaction and has extensive expertise on tax legislative developments. In Houston, Jason McIntosh and John Lynch   advise clients across industry sectors, including investment funds, public and private companies, governmental entities, and high-net-worth individuals whilst George Gerachis represents clients before the courts concerning IRS audit and appeals. In New York, Ron Nardini concentrates his practice on the formation, operation, and investments of private equity, venture capital, and hedge funds, with a particular focus on credit, health care, entertainment and cross-border investments. Allyson Seger, who sits in the Austin office, focuses her practice on the US federal income tax aspects of complex cross-border and domestic transactions.

Practice head(s):

David Peck; Ryan Carney


Key clients

Baytex Energy Corp.


Riverstone Holdings L.L.C.


Global Infrastructure Management, LLC


Core Laboratories LP


Chevron Phillips Chemical Company LLC


FloWorks International LLC


Sumitomo Forestry America, Inc.


Ojo Labs, Inc.


Aviat Networks, Inc.


Swiss Life GIO III Holding S.à r.l.


Aligned Energy Holdings, LP


Work highlights


  • Advised Baytex Energy Corp., a Canadian company, in entering into a Merger Agreement to acquire U.S.-based Ranger Oil Corporation, a pure play Eagle Ford company for $2.5 billion.
  • Advised Aligned Data Centers and its sponsor Macquarie Asset Management in the execution of a definitive agreement to acquire ODATA, a data center service provider offering scalable, reliable, and flexible IT infrastructure in Latin America, from Patria Investments and other selling stakeholders.
  • Advised Global Infrastructure Partners (GIP) in the execution of a definitive agreement with Canadian-based TC Energy to acquire a 40% interest in its Columbia Gas Transmission, LLC (Columbia Gas) and Columbia Gulf Transmission, LLC (Columbia Gulf) systems, in a new joint venture, with total proceeds expected to be US $3.9 billion in cash.

Fenwick & West LLP

Fenwick & West LLP‘s Silicon Valley-based team has particular strengths in international tax planning, transfer pricing issues, and tax dispute resolution. The team often utilizes its global presence to advise domestic and cross-border clients with novel taxation issues. Transfer pricing expert Larissa Neumann has a broad practice routinely providing strategic advice on tax structuring, resolving tax disputes, and negotiating favorable tax transactions. David Forst concentrates his practice on international corporate taxation matters. Adam Halpern regularly advises on the 2017 TCJA, including FDII, GILTI, BEAT, and the new foreign credit system as well as on traditional international tax issues such as transfer pricing, cross-border M&A, international restructurings, Subpart F, source of income, and expense allocations. William Skinner has significant expertise in GILTI/subpart F, foreign tax credits, transfer pricing, tax treaties, and international restructurings and M&A. Mike Knobler‘s practice focuses on international and domestic corporate and partnership tax planning, M&A issues, and controversies. Julia Ushakova-Stein is well-versed in international tax planning, inbound and outbound controversy matters, the tax aspects of M&A, and transfer pricing. At the associate level, Ariel Love and Seattle-based Sean McElroy are names to watch.

Practice head(s):

Larissa Neumann


Testimonials

‘I work extensively with the Fenwick & West Tax team and find all of them to be outstanding advisors. Their advice is always technically sound and creative, and they communicate their thoughts in a natural, easy-to-understand manner. I’ve worked with tax lawyers with Wall Street law firms and with some of the best in-house tax lawyers, and my experience with the Fenwick & West Tax team is that the quality of their work is at least as good as (if not better than) the work of those other firms and lawyers.’

‘I have recently worked with David Forst and Sean McElroy. They are considered leaders in the Blockchain/Crpyto tax community. They have provided qualify and timely advice with respect to tax matters in this industry.’

‘I’ve worked most extensively with Julia Ushakova-Stein, Adam Halpern and Larissa Neumann at Fenwick & West and find that they are so easy to work with. Their overall dispositions are excellent, and they make working at times under pressure much easier. I have a lot of faith and trust in them, and they’ve delivered top-notch work every time I ask for their advice. Also, they have displayed to me how thoughtful they are in their work, and that attribute gives me a lot of comfort in working with them and continuing to rely on them.’

Key clients

Chinook Therapeutics


Figma


Meta


Univision


Whatnot


The Estee Lauder Companies


Paramount Global (formerly ViacomCBS)


Work highlights


  • Represented Meta as special tax counsel in its US$5.7 billion investment for a 9.99% stake in Jio Platforms, the biggest telecom operator in India and a subsidiary of multinational conglomerate Reliance Industries.
  • Advised Univision in its US$4.8 billion merger with Televisa.
  • Represents Whatnot on structuring and implementing its international tax structure and on various unique domestic tax matters considering the company’s business.

Karlin & Peebles

Los Angeles-based Karlin & Peebles is an ‘excellent, boutique law firm’ that has a specific focus on advising its high-net-worth and ultra-high-net-worth clientele in the areas of international taxation, estate planning, and charitable giving. The team is co-headed by Michael Karlin, who advises and represents businesses and high-net-worth individuals and families on taxation issues relating to cross-border matters, and Jane Peebles, who has experience advising domestic and foreign clients, charities, and philanthropists on estate planning matters. Cynthia Brittain advises clients on international income tax and estate planning issues as well as on the structure and reorganization of their multinational businesses in order to minimize worldwide taxes. Maria-Soledad Otero supports corporate clients seeking to optimize their worldwide effective tax rate and to reduce foreign taxes through tax-efficient financing, efficient cash management, repatriation of earnings to the US, and transfer pricing analyses. Kara Koerner joined the team in May 2023 from Weinstock Manion. At the associate level, Joohee Jung and Jiahua Wang are names to watch.

Practice head(s):

Michael Karlin; Jane Peebles


Testimonials

‘Exceptionally intelligent and informative lawyers. Ability to think outside the box. Exceptional analytical skills. Exceptional communicative skills. An in-depth knowledge of the law. Energetic, enthusiastic and down to earth.’

‘Michael Karlin- Exceptionally intelligent and informative lawyers. Ability to think outside the box. Exceptional analytical skills. Exceptional communicative skills. An in-depth knowledge of the law.’

‘Seamless collaboration among partners of the firm.’

Miller & Chevalier Chartered

Miller & Chevalier Chartered‘s Washington DC-based team supports clients with the tax matters throughout the full lifecycle of their cross-border operations from acquisition or start up, to restructuring, tax optimization, termination, and disposition. The team also advises advise companies, trade organizations, and governments on international tax policy matters, including related to the OECD’s Base Erosion and Profit Shifting (BEPS) project. Department head Layla Asali advises on the federal income tax aspects of cross-border transactions and business activities as well as advising on the international tax issues of M&A, IP transactions, supply chain planning, and financings. Rocco Femia represents large, multinational corporate clients in high-stakes international tax and transfer pricing planning, controversy, and policy matters. Loren Ponds concentrates her practice on providing strategic advice on legislative, regulatory, and other tax policy issues as well as advising on technical tax matters relating to transfer pricing. Jeffrey Tebbs supports multinational companies on complex tax planning matters for various transactions, including acquisitions, dispositions, restructurings, and joint ventures, and represents businesses in related tax controversies. Caroline Reaves advises on the tax aspects of cross-border acquisitions, dispositions, debt financings and restructurings, and various tax controversy matters. Samuel Lapin focuses his practice on working with clients during IRS audits and before the IRS Independent Office of Appeals on a variety of issues, including the R&E credit, partnership basis adjustments, management fee waivers, charitable contributions, and collection and penalty issues.

Practice head(s):

Layla Asali


Key clients

American Fidelity Assurance Company


British Airways PLC


Garmin Ltd.


Nokia of America Corporation


Semiconductor Industry Association


Work highlights


  • Advising the SIA with respect to tax-related legislative and policy matters.

Morrison Foerster

The tax team at Morrison Foerster handles tax matters relating a wide range of issues, encompassing M&A, private equity, venture capital, REITs,  tax treaties, and tax controversies. Practice head Anthony Carbone, who is located in New York, advises clients on tax planning strategies for M&A, reorganizations, fund formation and leveraged buyouts representing private equity funds, deal sponsors, investment banks, commercial banks and hedge funds, as well as venture capital, real estate and other funds, acquiring and target companies, and management groups. Dave Sturgeon supports clients with a wide range of complex business transactions, including domestic and cross-border M&A, joint ventures, spin-offs and other divestitures, as well as financings, refinancings, restructurings and other business transactions. Federal tax expert Joy MacIntyre, who is based in San Francisco, concentrates her practice on providing tax planning and transactional advice to U.S. and non-U.S. based businesses and their investors. Also based in San Francisco, Bernie Pistillo advises on the US federal income tax aspects of international and domestic M&A, corporate restructurings and spin-offs, and tax controversy matters in the international area, particularly transfer pricing, the development and exploitation of technology and intellectual property and the structuring of international operations for both start-up entities and existing corporate groups. San Diego-based Shane Shelley has significant experience counseling on the tax aspects of business transactions, including M&A, fund formations, joint ventures, international structuring and capital markets offerings. In New York, Katherine Erbeznik has a particular focus on the Latin America market, routinely advising on cross-border M&A. At the associate level, Lauren Keller, who sits in the Los Angeles office, is a name to watch.

 

 

 


Practice head(s):

Anthony Carbone


Testimonials

‘Experts in their field, very accessible, great sector/industry knowledge, friendly. I consider them to be business partners.’

‘Katherine Erbeznik is the best tax attorney I have worked with in the last 10 years.’

 

Key clients

Arm Holdings Ltd.


SoftBank Group Corp


eBay


onsemi


McGrath RentCorp


Southwest Gas Corporation


Veeco Instruments Inc.


Odevo AB


Anzu Special Acquisition Corp I


Vontier Corporation


Trilon Group


Dosatron International


Era Software


Nikon Corporation


Alpine Investors


Rubicon Technology Partners


Grant Thornton


Alexandria Real Estate Equities, Inc.


Antarctica Capital LLC


Autodesk


RH (formerly known as Restoration Hardware)


UDR, Inc.


Unity Technologies


Work highlights


  • Advised Arm on tax matters relating to its blockbuster IPO on the Nasdaq Global Select Market.
  • Advised SoftBank Group Corp. on the tax aspects of its agreement to sell its 90.01% equity in Fortress Investment Group to Mubadala Investment Company, through its wholly owned asset management subsidiary Mubadala Capital.
  • Advised Southwest Gas on the tax implications of several strategic transactions, including the $1.5 billion sale of MountainWest Pipelines Holding Company to Williams Companies.

Reed Smith LLP

Reed Smith LLP’s global corporate group has notable strengths in the tax aspects of cross-border acquisitions, disposals, restructurings, joint ventures, and structuring of offshore private investment vehicles, including private equity and hedge funds. The team is co-led by New York-based James Tandler and Angelo Ciavarella, who both have expertise in M&A and divestitures including tax-free spin-offs, restructurings, tax-free reorganizations, leveraged buyouts and joint ventures. In Houston, Ron Scharnberg advises clients on federal tax matters while Robert Phillpott‘s practice focuses on advising clients on all areas of business taxation. Arnold Grant, who sits in the Chicago office, has expertise in tax aspects of renewable energy transactions. New York-based Simon Kliegman advises inbound and outbound multinational companies, individuals, and investment funds on domestic and foreign tax matters. At the associate level, New York-based Ari Byk and Washington DC-based Justin Hunter, who both advise on tax aspects on the full spectrum of cross-border corporate transactions, and New York-based Michelle Min, who focuses on US federal tax issues in cross-border transactions, are key names.

Practice head(s):

James Tandler; Angelo Ciavarella


Testimonials

‘Reed Smith’s tax attorneys are first rate. They have a keen grasp of the tax law but also bring a practical approach to any problem. They rank right up there with the best law firms in the US when it comes to tax.

‘Angelo Civarella is an outstanding tax partner. He is careful and creative in serving clients. He knows a wide range of tax provisions and has great experience. There are none better.’

 

Steptoe LLP

Steptoe LLP‘s Washington DC-based team, co-headed by Phil West and Beth Tractenberg, has considerable experience supporting clients with a broad range of issues, including tax policy, advice on qualified opportunity zones, blockchain and cryptocurrency taxation, taxation in the Metaverse, private client work, transactional taxes, income tax, transfer pricing and tax structuring for corporate transactions. The team also has particular strengths litigating before the Tax Court, Court of Federal Claims, district courts, courts of appeals, and the US Supreme Court as well as representing clients’ interests at the Treasury and the IRS. West advises major multinationals and high-net-worth individuals on international tax issues including complex and high-profile tax controversies, competent authority proceedings, and advising cross-border tax planning, tax treaties, foreign tax credits, and transfer pricing. Tractenberg focuses her practice on all aspects of personal representation of HNWI and families, routinely advising on international estate planning, cross-border and pre-immigration planning, gifting, and other tax issues. Amanda Pedvin Varma advises US and foreign businesses, family offices, and HNWI on the US tax consequences of cross-border tax planning, investments, reorganizations, business restructurings, acquisitions, and financings. Lauren Azebu concentrates her practice on US federal income taxation issues for domestic and international clients, including HNWI.

Practice head(s):

Phil West; Beth Tractenberg


Other key lawyers:

Amanda Pedvin Varma; Lauren Azebu


Key clients

American Astronomical Society


Council on Foundations


Sullivan & Worcester LLP

The international tax practice at Sullivan & Worcester LLP has extensive experience in strategic tax planning and implementation for a wide range of multinational corporations including cross-border M&A, restructuring, and global tax controversy. The Boston-based team also has strengths in international taxation matters for individuals including international trust and estate counselling for high net-worth families and pre-US residency tax planning. Practice head Douglas Stransky has a special focus on domestic clients investing in foreign jurisdictions and has extensive expertise advising clients on the tax implications of multi-jurisdictional cryptocurrency and fintech-related ventures. Lewis Greenwald has considerable experience advising on tax-efficient acquisitions, transfer pricing planning, and US international tax compliance. Eric Rietveld concentrates his practice on the tax planning of REITs, real estate funds, and international tax. Brian Hammell departed in August 2023.

Practice head(s):

Douglas Stransky


Other key lawyers:

Lewis Greenwald; Eric Rietveld; Marc Stern


Testimonials

‘The International Tax department at Sullivan & Worcester LLP demonstrates a thorough and detailed approach in addressing inquiries, ensuring that clients receive comprehensive responses to their questions.’

‘Focusing on individual contributions, Lewis Greenwald stands out as an exemplary member of the team. His expertise and trustworthiness are evident in every interaction. What sets Lewis apart is his exceptional ability to orchestrate collaboration within the team and across the firm, ensuring that clients receive well-rounded and balanced legal advice. His knowledge and skill in navigating complex tax matters are commendable, making him a valuable asset not only to the team but also to clients seeking expert guidance in international tax matters.’

‘The practice is unique in that the people have both a broad base of tax knowledge as well as an Indepth knowledge of the key areas of tax that are typically encountered by Multinational Companies. The team also has relationships with many other tax professionals in a just about every jurisdiction in the world where most USA Multinationals operate. These professionals are able to give you a basic foundation for operating in a foreign jurisdiction and the key areas that are different than USA and other Western countries.’

‘I’ve been working with several of the partners and have always enjoyed their high professionalism and speedy conduct. Doug Stransky is one of the best in the business, and Amy Sheridan knows her way around US executive comp and equity-based comp to employees and has a long track record working with Israeli based companies.’

‘The most important thing for me about the work the individuals provide is that they stay on point and understand the issue that we are working with them on. They are able to provide insights and engage with us in meaningful conversations that provide executive decision makers with the information they need to make their business decisions.’

‘Doug Stransky is one of the best in the business, professional in both US federal law and international taxation rules. Working with him is always a pleasure and the results for the client are great. Amy Sheridan is an expert in her field and has particular expertise working with Israeli based companies.’

Key clients

The Broadstone Group LLC


Iron Mountain Incorporated


Equinix, Inc.


Lionbridge Technologies, Inc.


Altra Industrial Motion


E Ink Corporation


Standex International


DarioHealth Corp.


International Transportation Marine Office, LLC


Work highlights


  • Represented The Broadstone Group; this project raises both corporate and individual tax issues in multiple countries that have to be balanced, coordinated and analyzed to ensure the most tax efficient results.

Withers LLP

Withers Bergman LLP utilizes a global platform and expertise in privately held capital to support multi-generational, high net worth, and ultrahigh net worth families with their cross-border taxation matters. The team is co-led by William Kambas, who splits his time between the New Haven, Greenwich, and New York offices, California and Texas-based Michael Brophy, and Jason Dinwoodie, who sits in the New Haven office. Kambas concentrates his practice on international tax planning for multi-national and multi-state personal, active business and investment activities with a particular emphasis on tax structuring and choice of business entity for US and non-US business owners and investors. Michelle Graham, who is based in San Diego, currently counsels several of Mexico’s wealthiest families in tax structuring and compliance as well as advising on sophisticated planning issues for family businesses, including structuring and implementing intra-family sales, buy-sell agreements and family business succession planning. David Stein, who sits in the New Haven, New York, and San Francisco offices, routinely advises US and non-US single-family offices, fund managers, and young entrepreneurs on cross-border restate planning and income tax advice. Also in San Francisco, Marsha Dungog supports with cross-border tax planning and tax compliance for HNW individuals, families, founders, executives and entrepreneurs. Los Angeles-based Paul Sczudlo concentrates his practice on global planning matters, including cross-border and entertainment tax planning. Alistair Christopher, who is located in New Haven, specializes in international and domestic tax and estate planning.

Practice head(s):

William Kambas; Michael Brophy; Jason Dinwoodie


Linklaters LLP

Linklaters LLP advises corporations, private equity houses, investment funds and sovereign wealth funds, both US and non-US headquartered, on a wide range of cross-border transactions, with a special focus on private equity, M&A, energy and infrastructure, capital markets, financial products, and corporate tax planning. The tea is headed by New York-based Max Levine who has experience advising private equity funds on a wide range of strategies, including structuring tax efficient lending, distressed debt, structured credit, real estate, infrastructure, and renewable energy investments. Michelle Lo routinely advises on variety of corporate tax issues, including tax free reorganizations and spin offs as well as taxable acquisitions and dispositions, in both domestic and cross border transactions. Gabriel Grossman has a broad finance and structuring tax practice with particular expertise in tax issues faced by renewable energy developers and sponsors, financial institutions, alternative investment funds, and institutional investors. Amanda Gabai, who joined the New York office from an in-house position May 2023, specializes in structuring alternative investment funds, including private equity, infrastructure, real estate, and debt funds. in Washington DC, Sean McKeever has significant experience representing multi-national clients on a variety of tax transactions, including M&A, dispositions, restructurings, spin-offs and liquidations.

Practice head(s):

Max Levine


Testimonials

‘People are very knowledgeable about not only tax, but practical considerations and international tax aspects as well. ’

‘Very responsive, friendly, available and knowledgeable.’

 

Key clients

Aermont Capital LLP


Getir


Ameriprise Financial


Banco do Brasil S.A.


Barings


B. Innovation X Advisors


Centerbridge Partners


Citi


Digital Bridge Group Inc.


DRA Advisors LLC


Goldman Sachs


HODL Capital


Kohlberg Kravis Roberts & Co. L.P. (KKR)


Macquarie


Partners Group


QIC


SMBC


SoftBank


Work highlights


  • Represented Barings on the structuring and fundraising for the latest generation of its global lending fund, North American direct lending fund and special situations fund (among other funds).
  • Advised Getir on its acquisition of FreshDirect from Ahold Delhaize USA.
  • Represented Aermont Capital on the establishment of its fifth real estate fund, Aermont Capital Real Estate Fund V SCSp, which targets opportunistic real estate and real estate related investments within Europe.

Troutman Pepper

Troutman Pepper represents private equity funds, portfolio companies, and public and private companies in a wide range of international tax related transactions and matters including M&A, refinancing, repatriation strategies, IPOs, restructurings, and management company transactions. Practice head Joan Arnold routinely advises on corporate and partnership taxation, corporate and private investment fund formation, and tax planning. Howard Goldberg supports US and international businesses and their principal stakeholders to optimize tax results in connection with life-cycle transactions. Morgan Klinzing has a special focus on federal and international income tax and private equity matters. All lawyers mentioned are based in Philadelphia.

Practice head(s):

Joan Arnold


Other key lawyers:

Howard Goldberg; Morgan Klinzing


Key clients

Littlejohn & Co. LLC


American Tire Distributors, Inc.


NearU Services


SSI Diagnostica Group


Apax Partners LLP