• Folder
  • Folder
  • Search
    Close
Close
Close
A B C D E F G H I J K L M N O P Q R S T U V W X Y Z
Close

Latest News

Recent Publications

Upcoming Events

Recent Videos

Federal & International Tax

  • Print
  • Email
  • Significant structuring/planning for a private investor’s activities in numerous jurisdictions in Europe, Asia and South America.
  • Advice with respect to a $30 million tax-sharing agreement dispute arising out of a spun-off subsidiary of a U.S. multinational company.
  • Advice with respect to the restructuring of a $300 million PIK note for a U.S. public company.
  • Highly sophisticated transfer pricing advice for major Asian and European manufacturing companies, including the securing of bilateral and multilateral advance pricing agreements.
  • Represented a foreign multinational client in connection with a proposed IRS transfer pricing assessment of $800–900 million, which resulted in a complete withdrawal by the IRS of its proposed assessment.
  • Structured U.S. real estate funds on behalf of foreign investors and global private equity funds on behalf of U.S. investors.
  • Advise with respect to cross-border financing transactions for major U.S. banks.
  • Advised a major foreign multinational group in the financial services area with respect to its internal restructurings and treaty tax planning.
  • Represented a publicly held German biotech company with respect to a spin-off transaction.
  • Advise a major foreign banking association with respect to the IRS Qualified Intermediary system and the new Foreign Account Tax Compliance Act.
  • Provided tax opinions with respect to a foreign investment in a master limited partnership in both physical and derivative form.
  • Advised a U.S. group with respect to a new tax-advantaged supply chain structure.
  • Represented a major independent energy company in connection with the tax aspects of an unwind of a complex, hybrid bond structure.
  • Advised with respect to the implementation of an acquisition structure involving a recapitalization and management rollover.
  • Represented a U.S. company in connection with the tax free combination of its two U.S. consolidated groups.
  • Advised a U.S. group on a complex restructuring of its capital structure in anticipation of an IPO.
  • Representation of significant public REITS with respect to qualification issues, including the handling of a multimillion-dollar audit.
  • Provided advice to a U.S. company in structuring, designing and implementing a highly tax advantaged deferred compensation “long-term incentive plan” for senior executives.
  • Representing a U.S.-based company with respect to a multimillion-dollar refund action in federal court.
  • Handled a tax audit for a U.S. multinational resulting in a 100 percent concession by the IRS of a proposed multimillion-dollar assessment.
  • Handling a matter at IRS Appeals involving the highly complex dual consolidated loss rules.
  • Handling a $40 million issue arising in an IRS audit of a REIT.
  • Handling a $250 million debt/equity classification case before the IRS.
  • Representing a number of high net-worth clients in the IRS Voluntary Disclosure Program with respect to their offshore accounts and assets.
  • Represent a major hedge fund and private equity funds with respect to structures and strategies, including tax advice on behalf of foreign and tax-exempt investors.
  • Representation of a U.S. multinational company with respect to a large asset/interest sale.
  • Advice provided to securitization and trustee clients, as well as to banks, with respect to REMICs, offshore CDOs, commercial lending and other financing structures.
  • Handled the acquisition of a $600 million manufacturing facility through a Chapter 15 bankruptcy, with attention paid to carryover of tax attributes to the buyer.