United States

United States > Leading tax law firms


There were several developments and talking points in the tax arena in 2016. Firstly, there was the continuing trend of the tax authorities seeking to close loopholes to prevent tax avoidance. For example, the US Treasury Department reformed the rules on tax inversions in order to prevent US companies from establishing their headquarters abroad and employing post-inversion maneuvers (such as earnings stripping). This had a major impact on the market for large-scale tax inversions, such as Pfizer’s proposed $160bn acquisition of Ireland-incorporated Allergan, which was ultimately scrapped.

The tax authorities also went after base erosion and profit shifting (BEPS) strategies, which exploit gaps in the international tax framework to effectively avoid tax. This increased the compliance burden for multinationals and thus initiated reviews and new implementations in tax planning - especially regarding transfer pricing and the way companies manage (and report) the profits gained domestically and by their foreign subsidiaries. As a result, law firms reported an increase in transfer pricing cases both domestically and internationally, and many practices increased their resources to handle such cases.

Also intended to cut tax avoidance were the final regulations announced by the Internal Revenue Service (IRS) regarding property owned by controlled foreign corporations and partnerships; this also generated a significant uptick in enquires for law firms.

In the financial products space, a key talking point was the continued strength of the private equity space during 2016, with total investment of $158.1bn into US targets, marking a 7.5% increase. The current top sectors include technology, energy and utilities, as well as industrials and chemicals. There has also been a higher demand for advice on specialty finance products, such as healthcare financings.

In October 2016, in what was a significant development, the US Treasury and the Internal Revenue Service issued its hotly anticipated final and temporary regulations on how certain debt instruments will be characterized for US tax purposes - revising earlier proposals that were met with considerable resistance. These final regulations maintain the basic framework of proposals but narrow the scope in ways that are beneficial to private equity funds.

In terms of other regulations, the equity securities market faced changes with the introduction by the IRS of Section 871(m), which came into effect at the beginning of 2017. The new rule is intended to prevent the avoidance of withholding tax on dividends paid by US corporations, which means that payments on these financial instruments are subjected to a withholding of 30% tax. In the CLO space, the US risk retention rules for asset-backed securities (which became active in December 2016) require the collateral managers in transactions to hold a specific percentage of the value.

Looking at tax law in light of the new Trump administration, a complete reform has been proposed that would introduce lower US corporate rates - down from 35% to 15% - as well as enforce repatriation from companies holding offshore profits. Trump’s tax adviser, Stephen Moore, stated in an interview that the latter rule would function to encourage former US companies now registered in Europe to return to the US and benefit from lighter taxes.

Financial products

Index of tables

  1. Financial products
  2. US - TDH500
  3. Next generation lawyers

US - TDH500

  1. 1
    • David Hariton - Sullivan & Cromwell LLP
    • Thomas Humphreys - Morrison & Foerster LLP
    • Andrea Kramer - McDermott Will & Emery LLP
    • Mark Leeds - Mayer Brown
    • David Miller - Proskauer Rose LLP
    • Erika Nijenhuis - Cleary Gottlieb Steen & Hamilton LLP
    • James Peaslee - Cleary Gottlieb Steen & Hamilton LLP
    • Robert Rudnick - Shearman & Sterling LLP
    • Avishai Shachar - Davis Polk & Wardwell LLP
    • Michael Shulman - Shearman & Sterling LLP
    • Po Sit - Davis Polk & Wardwell LLP
    • Kirk Wallace - Skadden, Arps, Slate, Meagher & Flom LLP

Next generation lawyers

  1. 1
    • Dennis Caracristi - Freshfields Bruckhaus Deringer LLP
    • Alan Schwartz - McDermott Will & Emery LLP
    • Jason Schwartz - Cadwalader, Wickersham & Taft LLP
    • Michael Seaton - Clifford Chance
    • Nathan Tasso - Shearman & Sterling LLP
    • Mark Yopp - McDermott Will & Emery LLP

Gary Silverstein and head of tax Linda Swartz now lead the financial products practice at Cadwalader, Wickersham & Taft LLP, following the departure of David Miller to Proskauer Rose LLP. The New York-based team focuses on securitization, debt issuances, mortgage finance and collateralized loan obligations (CLOs). Silverstein advised Deutsche Mortgage & Asset Receiving Corporation on a $975m securitization of a pool of 30 fixed-rate loans, while Mark Howe is acting for multiple financial institutions in the ongoing issuance of structured products. Special counsel Jason Schwartz served as an adviser to Oak Hill Advisors in connection with repo financings and the securitization of portfolios of non-performing residential mortgage loans.

The nine-partner, New York-based team at Cleary Gottlieb Steen & Hamilton LLP includes key players James Peaslee and Yaron Reich. Peaslee served as underwriters’ counsel to Citigroup, Goldman Sachs, J.P. Morgan and Morgan Stanley during several issuances of mortgage-backed securities over the course of a year, worth $118.6bn. Erika Nijenhuis advised Credit Suisse Group on the offering of $2bn of senior notes due 2023. Corey Goodman became a partner in January 2016.

At Clifford Chance in New York, David Moldenhauer (noted for his ‘depth of knowledge’), Richard Catalano (‘extremely good at problem solving’), Philip Wagman (‘tireless and unflappable during difficult assignments’) and Michael Seaton are the key partners for financial products. Moldenhauer and Wagman advised the major shareholders of AB InBev on its acquisition of SABMiller, including on critical tax matters and deal financing, while Catalano provided assistance to Madison International regarding its Real Estate Liquidity Fund IV, targeting $1.35bn. Seaton supported Enstar Group and an investment manager of UBS in the formation of an alternative asset reinsurance company in Bermuda called Aligned Re. Donald Carden stepped down as partner and is now of counsel.

The New York-based tax practice at Davis Polk & Wardwell LLP is headed by Avishai Shachar and Neil Barr. Shachar advised Baker Hughes on its merger with General Electric’s oil and gas business. Rachel Kleinberg assisted the lead deal managers of GE with several exchange offers of common stock as well as the purchase of outstanding notes from some of their capital funding subsidiaries overseas, while Po Sit and Lucy Farr advised Morgan Stanley & Co on multiple SEC-registered global notes offerings totaling more than $16.5bn in 12 months.

Shearman & Sterling LLP’s financial products lawyers concern themselves with transactions, strategic tax planning, asset management and tax controversy. Co-leader Michael Shulman, who functions as the sole domestic outside counsel for the International Swaps and Derivatives Association (ISDA), as well as Robert Rudnick and Kristen Garry form the core team in Washington DC. Garry and Rudnick are representing the estate of Andrew J McKelvey, the founder of Monster.com, in a $41m deficiency dispute on gains from forward contracts with respect to Monster.com shares. Also noted are counsel Nathan Tasso, who supports Shulman in ISDA matters, and associate Jeffrey Tate, who represented Deutsche Bank, HSBC, J.P. Morgan and Santander as global coordinators and BBVA, Citibank and UBS as joint bookrunners in Argentina’s historic $16.5bn bond offering.

Skadden, Arps, Slate, Meagher & Flom LLP’s sizable financial products group consists of 11 partners (all based in New York) and handles both advisory and contentious matters. The global leader of the regulatory practice, David Rievman, advised Yahoo! on the $4.83bn acquisition of its operating business by Verizon and also supported DuPont in its combination with Dow Chemical in an all-stock merger of equals with an announced value of $130bn. Brian Krause is advising Atlas Resource Partners in a proposed pre-packaged Chapter 11 reorganisation plan to restructure its secured and unsecured funded debt.

Sullivan & Cromwell LLP’s New York-based financial products practice is led by Ronald Creamer, who recently advised AB InBev regarding its agreement with SABMiller to acquire all of SABMiller’s outstanding share capital, worth $71bn. Jeffrey Hochberg assisted SoftBank Group Corporation with its monetization of $8.9bn of its shares in Alibaba Group Holding through the issuance of exchangeable trust securities. Together with David Hariton, Hochberg regularly acts for the Federal Tax Committee of the Securities Industry and Financial Markets Association (SIFMA) in discussions with the Treasury Department and Internal Revenue Service (IRS) concerning new regulations; most recently, the rules regarding the tax treatment of equity derivatives.

Robert Culbertson and of counsel Kurt Baca in Washington DC are the key lawyers in Covington & Burling LLP’s financial products practice. Baca regularly advises major sports leagues and clubs on the structuring of financing arrangements as well as on tax accounting on debt and financial instruments. Other regular work includes bond structuring, restructuring of hedging programs and representing clients before the IRS. BNP Paribas, ING and Commerzbank are among the firm’s client base.

Clients of Freshfields Bruckhaus Deringer LLP include MSD Capital, London Stock Exchange Group, AstraZeneca and UBS Securities. Robert Scarborough in New York and Claude Stansbury in Washington DC lead the practice and handle matters concerning structured finance, equity and debt securities, internal tax investigations and the syndication of private investments, and they also serve as counsel to underwriters. Scarborough advised WireCo WorldGroup on its $1bn-plus debt and equity recapitalization, including the refinancing $825m of existing debt and a $260m majority equity investment by Onex Capital. Another one of his highlights was acting for Morgan Stanley, UBS Securities, Keefe, Bruyette & Woods and RBC Capital Markets as underwriters during the issuance of preferred stock worth $145m by Chimera Investment Corporation, in which he was supported by counsel Dennis Caracristi. Stansbury supported ConvaTec in raising $1.8bn through an IPO and listing on the London Stock Exchange.

Mayer Brown’s practice is based across New York, Chicago and Charlotte and consists of 16 partners, who advise clients such as HSBC, Barclays and Macquarie Group on the development of new products and trading strategies. The ‘exceptional’ George Craven (an ‘expert on excise tax and permanent establishment rules’) advised Global Benefits Group on a possible private equity sale or IPO of stock of its parent company, while Mark Leeds (a ‘market-leading US tax adviser on equity-related matters’) assisted a leading investment bank with the systematization of withholding rules applicable to dividend equivalents paid on US stocks. Steven Garden, who represented the underwriters in a $1.6bn issuance of three classes of notes secured by mobile phone finance plans, was promoted to partner in January 2016.

The financial products team at McDermott Will & Emery LLP - based across New York and Chicago - has ‘considerable experience in the derivatives arena as well as a goal-oriented approach to tax planning’. The firm advises investment banks, businesses and high-net-worth individuals on financial transactions and product structuring, with a special focus on state and local tax (SALT), energy tax (such as advising Morgan Stanley on the acquisition, financing and development of solar photovoltaic systems), and tax related to finance and capital markets transactions. John Lutz, David Taub and Alan Schwartz assisted Deutsche Bank with an extensive internal project to restructure certain parts of its US operations to comply with the intermediate holding company regulations. Lutz also handles SALT matters for Barclays on a regular basis. Andrea Kramer has ‘unparalleled subject matter expertise and yet is refreshingly practical’ and William Pomierski has an ‘impressive ability to navigate the complex, interrelated fields of derivatives and benefit plans’.

Morrison & Foerster LLP’s financial products practice mainly acts for leading banks in relation to tax structuring, stock offerings, development of new products and tax investigations. Tax co-chair Thomas Humphreys in New York and Remmelt Reigersman in San Francisco advised Bank of America on a series of exchange agreements as well as over 100 debt issuances over the course of a year. They also supported Bank of Montreal in the development of new platforms for the issuance of structured products, and advised RBC Capital Markets on the US tax aspects of its issuances of a variety of structured notes, including equity-linked, commodity-linked and ETF-linked products. Associate David Goett is developing a specialism in the area and works with several banks on the tax aspects of a variety of capital markets transactions. In March 2017, Michelle Jewett moved to Stroock & Stroock & Lavan LLP.

At Sidley Austin LLP, financial products lawyer Robert Kreitman leads a team of four partners and 11 associates in New York. He recently advised JPMorgan Chase on its first securities offering entirely backed by its owned mortgages since the financial crisis, as well as Turkish Catastrophe Insurance Pool on its $100m Bosphorus catastrophe bond. David Miller and Nicholas Brown acted for Simon Property Group in a $1.35bn underwritten public offering of 5-year and 10-year notes and also in a $1.10bn underwritten public offering of 10-year and 15-year notes.

Jeffrey Koppele and Timothy Santoli are the key lawyers in Dentons’ New York-based financial products practice and handle risk-sharing, risk-transferring, security-lending and financing transactions. They both advised Xerium Technologies in a senior secured note offering worth $480m. Koppele acted for Bank of Tokyo MUFG in a 20-bank, $240m financing for Johnson Controls, and handled an accelerated stock repurchase transaction for James Hardie International Finance.

Linklaters LLP’s financial products practice, spanning New York and Washington DC, includes Gordon Warnke, Jasper Howard, David Brockway and Andrew Morris. Morris advised Wells Fargo Bank on its role as administrative agent under a $700m first-lien reserve-based lending facility to Atlas Resources Partners, while Warnke handled the sale of all shares from client Visa Europe to Visa, with a total matter value of €18.37bn. Warnke also supported Deutsche Börse in its €21bn all-share merger of equals with London Stock Exchange Group. Other clients include Saeta Yield and Société Générale.

Stroock & Stroock & Lavan LLP’s three-partner New York-based financial products team focuses on corporate and individual taxation, including in relation to bankruptcy and insolvency as well as private equity transactions. Head of practice Jeffrey Uffner represented J.P. Morgan Asset Management in structuring a complex Section 892-compliant tax-driven investment vehicle to permit a foreign investor and a domestic investor to each acquire interest in a private REIT and other corporate entities. Mayer Greenberg assisted PBF Holding Company with its $500m offering of secured senior notes, while Micah Bloomfield is acting for an ad hoc group of first lien bank lenders - holding a majority interest in Caesars Entertainment Corporation’s and Caesars Entertainment Operating Company’s $5.4bn of first lien term loans - in connection with Caesars’ $20bn Chapter 11s. Michelle Jewett joined from Morrison & Foerster LLP in March 2017.

International tax

Index of tables

  1. International tax
  2. US - TDH500
  3. Next generation lawyers
  4. Revenue authority details

US - TDH500

  1. 1
    • Kimberly Blanchard - Weil, Gotshal & Manges LLP
    • Andrew Braiterman - Hughes Hubbard & Reed LLP
    • Ronald Creamer - Sullivan & Cromwell LLP
    • Robert Culbertson - Covington & Burling LLP
    • Gary Friedman - Debevoise & Plimpton LLP
    • James Fuller - Fenwick & West LLP
    • Stephen Gordon - Cravath, Swaine & Moore LLP
    • Hal Hicks - Skadden, Arps, Slate, Meagher & Flom LLP
    • Kenneth Klein - Mayer Brown
    • Andrew Needham - Cravath, Swaine & Moore LLP
    • Paul Oosterhuis - Skadden, Arps, Slate, Meagher & Flom LLP
    • Yaron Reich - Cleary Gottlieb Steen & Hamilton LLP
    • David Rosenbloom - Caplin & Drysdale, Chartered
    • Leslie Samuels - Cleary Gottlieb Steen & Hamilton LLP
    • Robert Scarborough - Freshfields Bruckhaus Deringer LLP
    • Michael Schler - Cravath, Swaine & Moore LLP
    • Peter Schuur - Debevoise & Plimpton LLP
    • Andrew Solomon - Sullivan & Cromwell LLP
    • Davis Wang - Sullivan & Cromwell LLP
    • Lowell Yoder - McDermott Will & Emery LLP

Next generation lawyers

  1. 1
    • Daniel Altman - Sidley Austin LLP
    • Craig Cohen - Allen & Overy LLP
    • Tijana Dvornic - Wachtell, Lipton, Rosen & Katz
    • Christopher Fargo - Cravath, Swaine & Moore LLP
    • Ethan Harris - Shearman & Sterling LLP
    • Kai Kramer - Baker McKenzie LLP
    • Lee Morlock - Mayer Brown
    • Mark Schwed - Weil, Gotshal & Manges LLP
    • Julia Skubis Weber - Baker McKenzie LLP
    • Edward Wei - Cadwalader, Wickersham & Taft LLP

Baker McKenzie LLP’s large international tax team advises on M&A transactions, post-acquisition integrations, spin-offs and transfer pricing matters. Houston-based Jonathan Martin, who leads the practice alongside Chicago-based Jeff Maydew, handled a $1.8bn UK re-domiciliation transaction for Cardtronics, while San Francisco’s Kirsten Malm and John Peterson and Scott Frewing in Palo Alto supported Expedia in several matters, including the post-acquisition integration of Orbitz and HomeAway. In January 2016, six associates were promoted to partner, among them Kai Kramer in Houston and Julia Skubis Weber in Chicago. Following Peter Daub’s move to Morgan, Lewis & Bockius LLP, the team added four partners as well as director of economics Donna McComber, who joined the Washington DC office.

Clients who have worked with the ‘very good’ international tax department at Cleary Gottlieb Steen & Hamilton LLP single out James Peaslee and Yaron Reich for particular praise. James Duncan advised SABMiller on its merger with AB InBev, while William McRae handled Verizon Communication’s agreement to buy Irish company Fleetmatics Group for $2.4bn. Diana Wollman supported French supplier Air Liquide in its acquisition of Airgas, worth $13.4bn. Corey Goodman became a partner in January 2016. All named attorneys are based in New York.

Recent highlights for the international tax practice at Cravath, Swaine & Moore LLP include an asset swap between client AB InBev and Ambev - handled by head of tax Stephen Gordon, Lauren Angelilli and Christopher Fargo - in which the former will transfer SABMiller’s Panamanian business to the latter and the latter will transfer its business in Colombia, Peru and Ecuador to the former. Andrew Needham and J Leonard Teti handled numerous transactions for IBM, including its cross-border acquisition of Israel-based EZ Legacy. DreamWorks Animation, Goldman Sachs and Johnson & Johnson are also among the firm’s clients.

At Davis Polk & Wardwell LLP, Po Sit and Avishai Shachar are the foreign tax experts for Hong Kong, Taiwan and China and Israel respectively. Shachar advised global Swiss agribusiness Syngenta regarding a $43bn acquisition offer from ChemChina and, on the buyer’s side, he supported ExxonMobil during its acquisition of Papua New Guinea-based InterOil for $2.5bn. Michael Mollerus handled a debt offering worth $12.1bn for Shire that was conducted by its subsidiary Shire Acquisitions Investments Ireland, while Neil Barr assisted Chemtura Corporation with its $2.5bn acquisition by German chemicals group Lanxess. Barr leads the New York-based practice with Shachar.

Debevoise & Plimpton LLP’s clients in the international tax arena include American Airlines, The Carlyle Group, Verizon Communications and Kelso & Company. Key partner Michael Bolotin is an ‘incredibly knowledgeable and practical go-to person on complex international tax matters’, and the rest of the team ‘strives for continuity, is responsive and works well with others’. Peter Furci advised Cablevision on its $17.7bn sale to the Dutch Altice, while practice leader Burt Rosen and Gary Friedman acted for Italian investment company Exor during its $6.9bn acquisition of PartnerRe. ‘Outstanding international tax lawyer’ Peter Schuur supported StanCorp Financial Group in its $5bn sale to Japanese insurer Meiji Yasuda Life. All named attorneys are based in New York.

Under the global tax leadership of Nicholas DeNovio in Washington DC, Latham & Watkins LLP’s international tax practice handles large M&A deals as well as fund structuring and capital markets offerings. DeNovio supported FMC Technologies in the $13bn acquisition of and merger with Paris-headquartered Technip, to create TechnipFMC, while the Los Angeles-based Samuel Weiner advised The Carlyle Group on a deal to sell its portfolio company Landmark Aviation to UK-based BBA Aviation for $2bn. New York lawyer William Lu advised Goldman Sachs on acquisition financing and restructuring related to Vista Equity Partners’ purchase of Solera Holdings. Canada-based Caesars Interactive Entertainment and Lane Industries are new clients.

McDermott Will & Emery LLP’s international tax team advises on planning projects, M&A transactions, financings, joint ventures and restructurings for a client base that includes American Express, Fidelity, IBM and Walmart. Head of practice Lowell Yoder and Timothy Shuman assisted Luxembourg-headquartered JAB Holding Company with the $13.9bn and $1.35bn acquisitions of Keurig Green Mountain and Krispy Kreme, respectively. Mark Martin, Mark Horowitz and Andrew Roberson acted for British drilling company Ensco International in a transfer pricing examination, as it received adjustments of over $700m related to the value of rigs contributed to a UK partnership. Alongside Philip Levine, David Noren, Caroline Ngo and Kristen Hazel, Shulman advised Ireland-incorporated Tyco International on its $16.5bn reverse merger deal with Johnson & Johnson. Named attorneys are based in either Washington DC or Chicago.

Based across six US locations, Skadden, Arps, Slate, Meagher & Flom LLP’s team handles acquisitions, spin-offs, transfer pricing, dispositions, joint ventures, bankruptcy restructurings and financings. Kenneth Betts advised Bermuda-based MISA Investments on selling a 17% stake to TPG Capital and Canada Pension Plan Investment Board for $500 million, while Nathan Giesselman handled the merger between client Didi Chuxing and Uber China. Giesselman also advised Intel Corporation on the tax aspects of a strategic deal with joint venture partner TPG Capital to convert Intel Security into jointly owned cybersecurity company McAfee. Another major highlight was Washington DC-based Cliff Gross advising EMC Corporation on its acquisition by Dell for $67bn (the largest technology merger in history). Also in Washington DC, Hal Hicks and Paul Oosterhuis advised on separate matters for Biogen, such as a cross-border restructuring (handled by Hicks) and the tax-free spin-off of its hemophilia business (handled by Oosterhuis).

Sullivan & Cromwell LLP’s team is experienced in M&A transactions, restructurings and transfer pricing issues. Global head of tax Ronald Creamer advised on the $66bn acquisition of Monsanto by his client Bayer; a highlight deal that represented the largest all-cash takeover in history, the largest-ever acquisition of an American company by a foreign buyer, and the largest ever M&A transaction by a German company. Davis Wang advised Ferrari and Fiat Chrysler Automobiles on the spin-off of its ownership in Ferrari to Fiat Chrysler shareholders, while David Spitzer assisted Swiss insurer ACE Limited with its acquisition of The Chubb Corporation for a combined cash/stock consideration valued at approximately $29.5bn. All named attorneys are based in New York.

In 2016, the international tax practice at Mayer Brown hired the ‘exceptionally knowledgeable and accessible’ David Burton in New York from Akin Gump Strauss Hauer & Feld LLP, and also promoted Chicago-based lawyers Jonathan Hunt and Steven Garden to partner. Jason Bazar, Lee Morlock and Brian Kittle served as tax and structuring advisers to the Netherlands-based Altice Group regarding its agreement to acquire Cablevision. Morlock and Garden supported Yum! Brands in a spin-off that created two independent publicly traded companies called Yum! China and Yum! Brands. Michael Marion and Russell Nance from the New York office are also recommended. The team shines through its ‘responsiveness, thoroughness and expertise’ as well as its ‘excellent client relationships’.

Richard Bronstein and Jeffrey Samuels lead the ‘brilliant, responsive and keenly commercial’ international tax practice at Paul, Weiss, Rifkind, Wharton & Garrison LLP, which is based out of New York. Samuels, ‘a legend of the tax Bar’, recently worked on Time Warner Cable’s $78.7bn merger with Charter Communications, while Scott Sontag (who is ‘extremely strong’) advised Ontario Teachers’ Pension Plan during its investments in TierPoint and FarmTrust. David Mayo assisted Italy-based Exor with its $6.9bn successful cash bid for PartnerRe and supported UK-headquartered Mott MacDonald Group in separating its joint venture with Hatch. Other clients include Kohlberg & Company, MidCap Financial and Norwegian Cruise Line.

Shearman & Sterling LLP’s international tax practice advises on a variety of matters, such as multi-jurisdictional M&A transactions, tax structuring, tax controversy, investments as well as tax-sensitive company management/employee compensation packages and expatriate taxation. New York-based co-head Laurence Bambino advised Albemarle Corporation on the sale of its Chemetall surface treatment business to German company BASF in a cash transaction valued at approximately $3.2bn, while Ethan Harris in Washington DC led the tax advice regarding Liberty Global’s $5.5bn acquisition of UK-headquartered Cable & Wireless Communications. Menlo Park’s Larry Crouch assisted Taikang Insurance Group in establishing a joint venture with NorthStar Realty Finance Group. Bambino also advised Liberty Global on the distribution of 117.4 million Liberty Global Latin America and Caribbean ordinary shares to Liberty Global Group shareholders.

Simpson Thacher & Bartlett LLP’s strengths lie in M&A transactions, fund formation, financing and restructuring. Head of the largely New York-based team John Hart acted for Blackstone in the pending sale of Strategic Hotels to China’s Anbang for $6.5bn and also advised Centerbridge on the sale of Carefree Communities to Sun Communities for $1.7bn. John Creed supported The Carlyle Group in the establishment of a $2.4bn equity opportunity fund and the issuance of equity, while Jonathan Goldstein advised Microsoft on its announced $26.2bn acquisition of LinkedIn. California-based Katharine Moir acted for KKR & Co in its $345m issuance of 6.75% Series A preferred units in a SEC-registered offering.

Weil, Gotshal & Manges LLP’s international tax practice specializes in cross-border transactions, financings and debt restructurings. Jared Rusman in Dallas advised Sanofi on its pending $25bn exchange of its animal health business (Merial) for the consumer healthcare business of German Boehringer Ingelheim, while New York’s Kenneth Heitner handled the $13bn merger of equals between client IHS and UK-based Markit Limited. Brookfield Asset Management, General Electric and JAB Holding Company are also active clients. Kimberly Blanchard is assisting Ireland-based Avolon Holdings with its $10bn acquisition of the aircraft leasing business of CIT Group. Mark Schwed led a matter for Chinese HNA Group, which acquired a 25% stake in Hilton Worldwide Holdings for $6.5bn from affiliates of The Blackstone Group.

White & Case LLP’s tax department saw a number of changes in 2016, such as the appointment of Kim Boylan in Washington DC as global head of tax and the hire of Andrew Kreisberg from Gibson, Dunn & Crutcher LLP. At the beginning of 2017, New York lawyers Steven Gee and Kerry O’Rourke Perri were elevated to partner level. Head of national tax William Dantzler acted for Anthem in its $54.2bn acquisition of Cigna Corporation as well as Qingdao Haier in its $5.4bn acquisition of GE Appliances. Together with John Lillis, Kreisberg assisted Saudi Refining with the discontinuation of Motiva Enterprises and the division of Motiva’s assets, liabilities and businesses between Saudi Refining and affiliates of its joint venture partner, Royal Dutch Shell. Attorneys mentioned are based in New York except where otherwise indicated.

Clark Armitage and Patricia Lewis are the key partners for international tax at Caplin & Drysdale, Chartered. The core team, based in Washington DC, consists of seven partners and advises clients on transfer pricing, IRS examinations and international transactions. David Rosenbloom, who specializes in international tax planning and contentious matters, also served as an expert witness in numerous international tax disputes. Kirsten Burmester and Michael Pfeiffer both have notable experience advising high-net-worth individuals on structuring the taxation of their cross-border investments and estates, while Neal Kochman provides expertise in representations before tax authorities.

Clifford Chance’s international tax department, which is led out of New York by Richard Catalano, consists of seven partners and several other lawyers. David Moldenhauer and Philip Wagman advised AB InBev’s key shareholders on its $101bn acquisition of UK-based SABMiller. Alongside Emily DiStefano, Wagman also handled Global Jet Capital’s acquisition of General Electric’s entire North American corporate aircraft portfolio for $2.5bn. Sarah Jones led the joint acquisition of AdeS Alimentos de Soja by clients The Coca-Cola Company and Coca-Cola FEMSA from Unilever. Berkshire Group and Fidelis Insurance are additional clients. Donald Carden was transitioned from partner to of counsel.

At Covington & Burling LLP, clients recommend head of tax Daniel Luchsinger in Washington DC and capital markets lawyer Bruce Bennett in New York for delivering ‘excellent service in all areas’. The practice focuses on cross-border tax planning and restructuring, compliance and risk management, as well as controversy matters. The key lawyers-Luchsinger, Robert Culbertson, Samuel Maruca, Michael Caballero, William Chip and Dirk Suringa (all based in Washington DC)-advise clients such as Barclays, Commerzbank, General Electric and United Technologies Corporation.

Throughout 2016 and early 2017, DLA Piper LLP (US)’s ‘responsive, business-savvy and knowledgeable’ international tax department, which has a ‘geographic reach to almost all countries’, experienced a number of staff changes: New York lawyers Maruti Narayan, Drew Young and Frank Mugabi were all promoted to partner; in Palo Alto, Idan Netser joined from Fenwick & West LLP; and in Miami, Antonio Macias Valdes joined from KPMG Law LLP as a principal economist. Clients recommend co-heads Sang Kim, who is based in Palo Alto and hailed as ‘knowledgeable and resourceful’, and Sibel Owji, who is based in San Francisco and is ‘particularly strong in project management’. Also noted is the ‘experienced and proactive’ Michael Hardgrove in Boston and Palo Alto’s ‘creative’ Ben Olivas. Kim advised Qualcomm Incorporated on its $3bn joint venture with TDK Corporation and Hardgrove acted for Danaher Corporation in the separation into two independent, publicly traded companies via a tax-free spin-off.

At Dechert LLP, New York-based head of international tax Daniel Dunn advised Singapore sovereign wealth fund GIC on the joint acquisition with Silver Lake Partners of a substantial equity stake in Ancestry.com from existing equity holders, at an enterprise value of approximately $2.6bn, while Washington DC-based Michael Rufkahr acted for Bank of America Merrill Lynch Large Loan, Merrill Lynch, Pierce, Fenner & Smith, and Bank of America in connection with the securitization of a single commercial mortgage loan secured by the related borrowers’ fee and additional leasehold interests. Adrienne Baker in Boston regularly advises governments, trade associations, commercial banks, investment funds, investment advisers and multinational asset managers on the new Foreign Account Tax Compliance Act rules as well as sponsors on the formation of private equity funds.

The international tax practice at Fenwick & West LLPhas a very streamlined approach and unique insight into dealing with the IRS’ when it comes to transfer pricing and tax controversies. The ‘very responsive and timely’ team also handles M&A transactions and joint ventures, advising longstanding client Symantec on the $7.4bn sale of Veritas to the Carlyle Group and assisting Singapore’s GIC and China-based Tencent Holdings with the acquisition of an 84% stake in Finnish company Supercell from Japan’s SoftBank. James Fuller has been described as ‘the best tax attorney in the US’, and David Forst is ‘very knowledgeable and excellent to partner with’. The ‘very capable’ Larissa Neumann and ‘very good’ Andrew Kim are also recommended. All named attorneys are based in Mountain View.

Freshfields Bruckhaus Deringer LLP has a focus on inbound M&A transactions and also handles regulatory changes, investments and tax investigations. Claude Stansbury in Washington DC advised UK-based Henderson Group on its $6bn all-stock merger of equals with Janus Capital to form Janus Henderson Global Investors, while New York-based Robert Scarborough supported Zhongwang USA in its $2.33bn acquisition of Aleris Corporation from a consortium of shareholders led by Oaktree Capital Management and including Apollo Management and Sankaty Advisors. Scarborough, who leads the practice with Stansbury, also assisted Formula One Group and its shareholders with the sale of its 38.8% stake in Formula One to Liberty Media Corporation. Other clients include MSD Capital, Citibank and AstraZeneca.

The international tax group at Kirkland & Ellis LLP is based across the Chicago and New York offices. Dean Shulman, Mike Carew and Benjamin Schreiner together advised Baxalta Incorporated on its merger agreement with Irish company Shire in a $32bn transaction that created a leading rare-diseases platform, and acted for Molson Coors Brewing in its agreement with AB InBev to purchase for approximately $12bn SABMiller’s 58% stake in MillerCoors. Alongside Vincent Thorn, Carew and Shulman supported Micro Focus International in its $8.8bn Reverse Morris Trust acquisition of Hewlett Packard Enterprise Company’s software business. Russell Light assisted Solera Holdings with its $6.5bn sale to Vista Equity Partners.

Linklaters LLP has four partners and ten associates in New York and Washington DC focusing on international tax matters, and advising on acquisitions, dispositions, spin-offs and financings for clients such as Deutsche Börse, Centerbridge Partners Group and Visa Europe. The latter was advised by global head of tax Gordon Warnke during the sale of the entirety of its share capital to Visa for €18.37bn. Warnke also advised on Steinhoff’s acquisition of Mattress Firm Holding Corporation through a $3.8bn cash tender offer and refinancing. Andrew Morris is a regular fund and deal counsel to German-Swedish Triton Partners.

Sidley Austin LLP’s international tax practice in New York handles cross-border M&A transactions as well as restructurings and fund matters. Co-lead Laura Barzilai advised Singapore sovereign wealth fund GIC on its agreement to acquire a 19.9% interest in ITC Holdings Corp from Fortis for $1.2bn, while Christian Brause and Daniel Altman acted for Markel Corporation in its acquisition of the assets of Bermuda insurance-linked securities investment fund manager CATCo Investment Management. Dominique Gallego joined from EY in April 2016.

Jodi Schwartz, Deborah Paul, Eiko Stange and Joshua Holmes are the key partners for international tax at New York firm Wachtell, Lipton, Rosen & Katz and advise on corporate reorganizations, acquisitions, spin-offs and other dispositions, financings, restructurings and joint ventures. Recent highlights include Schwartz advising Monsanto during its $66bn acquisition by Bayer and Paul assisting French Danone with the $12.5bn acquisition of WhiteWave Foods. Stange advised Tesla Motors on its acquisition of Germany’s Grohmann Engineering, while Holmes handled the $4.3bn merger between client Lions Gate Entertainment Corporation and Starz. Tijana Dvornic became a partner in January 2017.

Allen & Overy LLP’s international tax practice is based in New York, with Jack Heinberg and Dave Lewis the key partners. Lewis advised Spanish bottling company Coca-Cola Iberian Partners on its merger with the US and German equivalents Coca-Cola Enterprises and Coca-Cola Erfrischungsgetränke to form a new UK company, Coca-Cola European Partners. Together with Heinberg, he also advised Deutsche Börse on its $1.1bn sale of International Securities Exchange Holdings to Nasdaq. Thomson Reuters and Waterton Global Resource Management are also active clients.

The international tax team at Baker & Hostetler LLP in Washington DC principally comprises four partners and two associates handling M&A transactions, restructurings, transfer pricing as well as tax treaty and controversy matters. Other partners are located in Denver, Philadelphia and New York. Department head Paul Schmidt, John Bates and John Lehrer are the key figures.

Miller & Chevalier Chartered’s international tax team in Washington DC is led by George Hani, with key partners including Rocco Femia and Kevin Kenworthy. It advises on a variety of matters, such as cross-border M&A, transfer pricing, tax treaty matters, business reorganizations and joint ventures. Recent highlights include representing the Coca-Cola Company in the US Tax Court in a case contesting multibillion-dollar IRS transfer pricing adjustments and representing Bermuda-based Starr International Company in a district court refund suit involving the determination of tax treaty benefits. Counsel James Gadwood joined from Sullivan & Cromwell LLP in September 2016. Former firm chair Phillip Mann sadly passed away in March 2016.

Morrison & Foerster LLP’s international tax practice provides ‘exceptional dedication and expertise while managing client resources, and budgets well’. Bernie Pistillo (San Francisco), David Strong (Denver) and Joy MacIntyre (San Francisco) are advising longstanding client SoftBank on its internal restructuring, while San Diego-based Shane Shelley supported Global Logistic Properties (GLP) in its acquisition of a $4.55bn logistics portfolio from Industrial Income Trust, and later advised GLP on the injection of the portfolio into its fund management platform as well as the establishment of GLP US Income Partners II. Pistillo also advised VMware on the $67bn acquisition of its parent company EMC Corporation by Dell. The ‘knowledgeable’ Linda Arnsbarger in Washington DC is recommended. Michelle Jewett moved to Stroock & Stroock & Lavan LLP.

In international tax matters, the New York-based team at Paul Hastings LLP advises clients such as Brookfield Investment Management, Credit Suisse, Fortress Investment Group and Platinum Equity. The chair of the tax department, Andrew Short, advised Japanese Takeda Pharmaceutical Company, Bay City Capital and Deerfield Management on the launch of Bridge Medicines, a new drug discovery company, while Joseph Opich advised Suddenlink Communications on its sale to French company Altice Communications in a transaction valued at $9.1bn. Alexander Lee, who recently left for McDermott Will & Emery LLP, supported FountainVest Partners on the establishment of a joint venture with WME IMG, Sequoia Capital China and Tencent. Synchrony Bank and Hyundai Asset Management are new clients for the department.

In April 2016, fund formation expert David Miller joined Proskauer Rose LLP’s tax team in New York from Cadwalader, Wickersham & Taft LLP. Recent highlights for the practice include Martin Hamilton advising Canadian company Pacific Exploration & Production on its acquisition by The Catalyst Group and its restructure through bankruptcy cases, refinancings and debt resolve. Hamilton and Stuart Rosow advised Spain-based Grifols on its acquisition of a 49% interest in Interstate Blood Bank, and the team also worked on matters for Adams Street Partners, Ares Management and Freshstream Capital. Mary Kuusisto relocated to the firm’s London office.

In February 2017, Sutherland Asbill & Brennan merged with UK-headquartered Eversheds to create new international proposition Eversheds Sutherland (US) LLP. Atlanta-based Reginald Clark served as lead tax counsel to Coca-Cola Enterprises, providing tax opinions in connection with its combination with Coca-Cola European Partners. Head of tax Jeffrey Friedman, Robert Chase and Michele Borens (all working out of the Washington DC office) are also key lawyers in the international tax department, advising clients such as Comcast Corporation, Cox Enterprises and Great-West Life. Bradley Seltzer from Deloitte Tax joined the Washington DC office in summer 2016.

In Vinson & Elkins LLP’s international tax practice, Stephen Jacobson in Houston was promoted to partner, while Christopher Mangin joined the Richmond office from Hunton & Williams LLP and Natan Leyva joined in Washington DC from EY. The practice has special expertise in the formation of master limited partnerships and taxation in the energy sector, but also handles equity and debt capital raising transactions, M&A, business reorganizations and joint ventures. David Peck (Dallas) and Boyd Carano (Houston) advised Talos Energy on its participation in round one of bidding for exploration and production contracts for projects in shallow waters off Mexico’s shore. Other clients include Big Star Oil & Gas, Core Laboratories Holding, Enviva Partners and International Paper Company.

The international tax department at Baker Botts L.L.P., which has a focus on the technology and energy sectors, is led by Richard Husseini and Derek Green in Houston. Green assisted Schlumberger with tax matters regarding its definitive stock-and-cash merger agreement with Cameron International Corporation, while Washington DC-based Don Lonczak advised Cobalt International Energy on a sale and purchase agreement with Sonangol. Tamar Stanley (also based in Washington DC) and Green also worked on the $8bn acquisition of Formula One by client Liberty Media from a consortium of sellers led by CVC Capital Partners Group. Hines is also a client.

Linda Swartz leads Cadwalader, Wickersham & Taft LLP’s international tax practice, which is based across New York and Washington DC. The lawyers handle complex M&A structures, spin-offs, inversions, Reverse Morris Trusts, divestitures and joint ventures. Swartz and Edward Wei, who was promoted to partner in January 2017, advised Procter & Gamble as special tax counsel on the split-off and tax-free merger of its global fine fragrances, salon professional, cosmetics and retail hair color businesses as well as its specialty beauty brands with Coty in a Reverse Morris Trust transaction. The pair also advised The Medicines Company on its sale of three of its marketed cardiovascular products and related assets to Italian pharmaceutical company Chiesi Farmaceutici.

Chadbourne & Parke LLP’s New York-based tax practice represents clients such as Macquarie, Tenaska and GLF Lenders. Michael Masri advised Deutsche Bank on the debt financing of Apex Clean Energy’s 217MW renewable portfolio deal, while head of the team William Cavanagh acted for InterAmerican Development Bank in a secured lending to finance a portion of the construction costs of the second line of the Lima and Callao metro project in Lima, Peru.

The international tax department at Curtis, Mallet-Prevost, Colt & Mosle LLP handles mergers, acquisitions, reorganizations, spin-offs, tax controversies, litigation and tax-related arbitration. Apart from team lead Alan Berlin, there are three other key partners in New York. Chairman George Kahale represents the government of Uganda in a series of arbitrations concerning contractual provisions regarding the taxation of sales and assignments of participating interests in petroleum agreements. Carl Ruggiero, Marco Blanco (who works in the Paris office), Shaun Reader and London-based Thomas Laurer advised the Private Equity Fund Origination Group at Merrill Lynch on the formation and launch of a series of feeder investment funds, such as the Blackstone Real Estate Partners VIII Feeder Funds (worth $352m) and the Carlyle US Equity Feeder Funds (worth $183m).

Marc Teitelbaum and John Harrington lead the international tax team at Dentons, which is based across six locations and advises on cross-border transactions, investments and transfer pricing matters. Teitelbaum and Timothy Santoli advise longstanding Brazilian client Gávea Investimentos on its operations and investments, most recently in a complex transaction that would give control of the management company back to its founders. Harrington advised Mayfair Games on the sale of Catan Studios to French game publisher Asmodee, while Jeffrey Koppele assisted Mizuho Trust & Banking Corporation with a cross-border securities loan worth $500m involving the US, UK and Belgium. Cayman National Corporation is also a key client.

Greenberg Traurig, LLP’s international tax practice consists of ten key partners in the US and five additional attorneys in the Netherlands. The lawyers focus on M&A transactions, joint ventures, structuring, investments, licensing, transfer pricing and treaty issues. New York lawyer Mary Voce is the chair of the practice; Seth Entin and Ozzie Schindler in Miami as well as Kenneth Zuckerbrot in New York and Robert Simon in Denver and Washington DC are other names to note.

Practice head Andrew Braiterman and Alexander Anderson are the main partners in the New York-based international tax practice at Hughes Hubbard & Reed LLP. Braiterman advised Cenveo on the $105m sale of its folded carton and litho-laminated display packaging business to a division of WestRock Company, while Anderson acted as debtor’s counsel to Republic Airways regarding its Chapter 11 restructuring, worth $3.5bn. Another highlight for Braiterman was advising on the acquisition of Pure Power Technologies from Navistar International Corporation by a UK-based investment group led by client Smithfield Group and Kensington Capital Partners. Anderson also advised Australia-based company Brambles on the combination of oil and gas container solutions businesses, Ferguson Group and CHEP Catalyst & Chemical Containers, with Hoover Container Solutions to create an independent joint venture company called Hoover-Ferguson Group.

In Kramer Levin Naftalis & Frankel LLP’s international tax practice in New York, the key partners are Barry Herzog, Pamela Capps and department head Howard Rothman. Herzog represents first-lien noteholders in the $11bn-plus Caesars Entertainment Operating bankruptcy, including handling all tax aspects of the restructuring, while Capps and Rothman advised Hydra Industries Acquisition Corp on its $200m acquisition of London-based Inspired Gaming Group. Maria Jones is another name to note. The client base also includes Stone Point Capital, AmTrust Financial and Steve Madden.

Norton Rose Fulbright US LLP’s international tax team was boosted in 2016 through its merger with Canadian firm Bull Housser. It also expanded in the US with the hires of Charles Hurley in Washington DC and Clifford Gerber in San Francisco from Mayer Brown and Sidley Austin LLP respectively. The team focuses particularly on M&A transactions in the energy, finance and healthcare sectors; for example, David Gillespie in New York advised Public Sector Pension Investment Board on its $1.2bn acquisition of FirstLight Power Resources Holdings from French Engie Group, and Stephen Kuntz acted for CeloNova BioSciences in the sale of its interventional radiology business to Boston Scientific. The US head of tax Robert Phillpott assisted Simmons & Company International with the $139m sale of 100% of its equity to Piper Jaffray & Co. Global tax head Andrius Kontrimas is based in Houston, as are Kuntz and Phillpott.

The key partners in Steptoe & Johnson LLP’s international tax practice are based in New York and Washington DC. Chairman Philip West and Amanda Varma advised several clients on tax treaties, foreign tax credits, internal restructuring transactions, as well as debt and equity issues, while team lead Robert Rizzi regularly acts for high-net-worth individuals and families in transactions and other cross-border issues. Zvi Hahn joined the team from Katten Muchin Rosenman LLP in August 2016.

The international tax practice at Sullivan & Worcester LLP in Boston provides ‘an excellent service and responds very speedily to clients’ needs’. Team lead Douglas Stransky is recommended for his ‘depth of knowledge, ability to explain things and understanding of transactions’. He provides ongoing advice to Broadstone Group and recently assisted the client in consultations with the Rio de Janeiro Olympics, including in relation to cross-border tax issues. Ameek Ashok Ponda and William Curry advise Iron Mountain and Equinix regarding their respective tax compliance and structuring issues. Another highlight for Stransky was advising on the $30m merger between Spanish client Alantra and CW Downer.

Tax practice leader John Cohn is the main point of contact at Thompson & Knight LLP for international tax issues. The team has a strong focus on energy-related matters and many of its clients are located in Mexico and the UK. Cohn and Todd Keator regularly advise Warwick Capital Partners on US business, including oil and gas acquisitions, divestitures and restructurings. Other clients include Vitro, Oil India and EnCap Investments. Tyree Collier was promoted to partner in January 2016 and Dean Hinderliter joined from Locke Lord LLP in May 2016.

US taxes: contentious

Index of tables

  1. US taxes: contentious
  2. US - TDH500
  3. Next generation lawyers

US - TDH500

  1. 1
    • David Aughtry - Chamberlain, Hrdlicka, White, Williams & Aughtry
    • Larry Campagna - Chamberlain, Hrdlicka, White, Williams & Aughtry
    • Jerold Cohen - Eversheds Sutherland (US) LLP
    • Miriam Fisher - Latham & Watkins LLP
    • Paul Frankel - Morrison & Foerster LLP
    • Fred Goldberg - Skadden, Arps, Slate, Meagher & Flom LLP
    • Roger Jones - McDermott Will & Emery LLP
    • Kathryn Keneally - DLA Piper LLP (US)
    • Kevin Kenworthy - Miller & Chevalier Chartered
    • Thomas Kittle-Kamp - Mayer Brown
    • Larry Langdon - Mayer Brown
    • Jerome Libin - Eversheds Sutherland (US) LLP
    • Raj Madan - Skadden, Arps, Slate, Meagher & Flom LLP
    • John Magee - Morgan, Lewis & Bockius LLP
    • Scott Michel - Caplin & Drysdale, Chartered
    • Mark Oates - Baker McKenzie LLP
    • Emily Parker - Thompson & Knight LLP
    • Jean Pawlow - McDermott Will & Emery LLP
    • Christopher Rizek - Caplin & Drysdale, Chartered
    • Duane Webber - Baker McKenzie LLP
    • Todd Welty - McDermott Will & Emery LLP
    • John Williams - Skadden, Arps, Slate, Meagher & Flom LLP
    • Joel Williamson - Mayer Brown

Next generation lawyers

  1. 1
    • Niles Elber - Caplin & Drysdale, Chartered
    • Larissa Neumann - Fenwick & West LLP
    • Mark Roche - Baker McKenzie LLP
    • Susan Ryba - Baker McKenzie LLP

Led by Robert Albaral in Dallas, Baker McKenzie LLP’s ‘outstanding’ practice has ‘extreme strength in depth’. The 70-strong team advises on all phases of international and domestic tax disputes. The ‘diligent’ Duane Webber in Washington DC is advising Altera Corporation on a high-profile challenge against the validity of a US Treasury regulation that required cost-sharing participants to share stock-based compensation. In Chicago, Thomas Linguanti and senior counsel Robert Cunningham led Medtronic in a $1.4bn transfer pricing dispute, and Andrew Crousore in Palo Alto successfully represented Nike in challenging Internal Revenue Service (IRS) deficiency notices regarding the allocation of taxes. The team represents a range of Fortune 500 companies, including names such as Starbucks, American Airlines, Pfizer and The Boeing Company. Palo Alto-based Scott Frewing has ‘a wealth of expertise’, Mark Roche in San Francisco is ‘excellent’ and Mark Oates and Susan Ryba in Chicago are also recommended. Colleen Romero in Chicago and Phillip Taylor in Washington DC were recently promoted to partner.

Caplin & Drysdale, Chartered’s ‘superb’ team advises on a range of criminal proceedings, offshore disputes and civil matters. The firm continues to represent hundreds of US citizens and residents in compliance issues arising from their failure to report foreign bank accounts, trusts and businesses. It is also advising the president and CEO of a company on an IRS criminal investigation into the failure to withhold and remit payroll taxes to the IRS. The ‘sharp’ Scott Michel heads the group in Washington DC, where Christopher Rizek is ‘excellent’ and Niles Elber is also recommended. The ‘brilliant’ Mark Allison leads the New York-based team, where Rachel Partain and Zhanna Ziering were recently promoted to the partnership.

Mayer Brown’s ‘superb’, 40-strong team is adept in high-profile tax litigation and is led by Joel Williamson and Thomas Kittle-Kamp in Chicago and Brian Kittle in New York. A team led by Kittle-Kamp is acting as co-counsel to Altera Corporation in its response to the IRS’s appeal of the US Tax Court’s decision invalidating some of the IRS’s transfer pricing regulations. Scott Stewart (Chicago) and Williamson represented Tyco International in the Tax Court in a dispute regarding the deductibility of interest paid by Tyco entities in the US to a related finance company in Switzerland. Boston Scientific, Tribune Media and Eaton Corporation are also clients. Chicago-based John Hildy and Palo Alto-based Larry Langdon are other key figures in the team. Jonathan Hunt in Chicago was promoted to partner. Chuck Hurley moved to Norton Rose Fulbright US LLP.

McDermott Will & Emery LLP’s ‘outstanding’, 40-partner practice is jointly led by Dallas-based Todd Welty, who is ‘first class’, and the ‘client-focused’ Jean Pawlow, who splits her time between Washington DC and Silicon Valley. In addition, the team has feet on the ground in Chicago, New York and Houston, and specializes in tax controversy, administrative appeals and tax litigation. Welty successfully acted for the John M Alterman Trust in a transferee liability case involving the sale of a family business. Led by the ‘focused’ Robin Greenhouse and others, the firm represented Illinois Tool Works in multimillion-dollar litigation regarding debt-equity issues and the substance of a repatriation transaction. The ‘exceptional’ Mark Martin heads the transfer pricing team from Houston, while in Chicago, Jane May is noted for state and local tax (SALT) matters, Roger Jones is ‘held in very high regard’, and Andrew Roberson is rated ‘excellent’.

The ‘exceptional’ department at Morgan, Lewis & Bockius LLP is led by Barton Bassett in Silicon Valley and Joshua Brady in Washington DC. The team is adept at handling complex disputes involving the IRS and state tax authorities, and is particularly noted for its transfer pricing expertise, in which Washington DC-based John Magee and Sanford Stark and Silicon Valley-based Bassett, Rod Donnelly, John Ryan and Bill Colgin are key figures. Magee and Stark are leading The Coca-Cola Company in a transfer pricing dispute, and are also acting for Amazon in multibillion-dollar transfer pricing litigation with the IRS. Alex Sadler, who recently joined from Ivins, Phillips & Barker, and the ‘formidable’ Sheri Dillon are also singled out for praise; both are based in Washington DC.

Based across several of its key US offices, Skadden, Arps, Slate, Meagher & Flom LLP’s team has a ‘fantastic reputation for tax controversy and litigation work’. Raj Madan (Washington DC), Nathaniel Carden (Chicago) and Emily Lam (Palo Alto) continue to advise Amazon on its high-profile transfer pricing dispute with the IRS. Madan is also advising Deutsche Bank Securities on an ongoing dispute involving a case brought by the Department of Justice (DOJ) in the Southern District of New York, seeking to collect a third party’s tax debt. Eaton Corporation, Ingersoll Rand and Marvel Entertainment are also clients. Among the ‘first-rate’ team, Washington DC-based Fred Goldberg, John Williams and Chris Bowers are also singled out for praise. Eric Sensenbrenner in Washington DC and Stuart Finkelstein in New York co-head the global tax group. Kenneth Gideon sadly passed away.

Based across the firm’s Atlanta, Houston, Philadelphia and San Antonio offices, Chamberlain, Hrdlicka, White, Williams & Aughtry is ‘an excellent tax litigation firm’ with ‘great trial lawyers’ and ‘top-quality individuals’. The 18-partner team represents taxpayers in all phases of the controversy and litigation process before the federal, state and local tax authorities. Larry Campagna is ‘one of the finest tax controversy lawyers in the country’ and advised US Exploration and Geo Fluorite Partners on a US Tax Court matter involving $100m of tax, penalty and interest. Kimberly-Clark Corporation, Live Nation Entertainment and UPS are also on the firm’s client roster. The ‘fantastic’ David Aughtry in Atlanta, George Connelly in Houston, and Philip Karter in Philadelphia jointly head the team. Former trial attorney at the DOJ’s Tax Division Kevin Sweeney joined as senior counsel in 2016, and Jaime Vasquez was promoted to partner.

The ‘astute’ Miriam Fisher in Washington DC, who has a ‘fantastic reputation’, heads the ‘experienced’ and ‘top-quality’ team at Latham & Watkins LLP, which is active across administrative proceedings and litigation, and has extensive experience in the US tax courts. DreamWorks Animation and its subsidiaries retained the team for a Court of Federal Claims matter regarding transition rules following the repeal of the extraterritorial income regime. The team is also advising Vento on a case which examines the nature of a ‘partner’ for federal tax purposes, and is acting for the Estate of Siegal in several pending tax cases involving oil and gas investment transactions. Brian McManus is ‘very able’ and is based across the firm’s Washington DC and Boston offices. Gerald Kafka has retired.

Washington DC-based firm Miller & Chevalier Chartered has an ‘excellent reputation’ and is particularly noted for its litigation prowess. Headline work for the ‘strong and very able team’ included representing The Coca-Cola Company in a case contesting multibillion-dollar IRS transfer pricing adjustments, and advising Starr International Company on a district court refund suit involving the determination of benefits under the US-Switzerland tax treaty. The team also acts for Washington Mutual in a number of disputes involving loss deductions for abandoned intangible assets. Among the team, Kevin Kenworthy is a ‘very experienced’ tax litigator, and Maria Jones, Steven Dixon and Kevin Downing are also noted. George Hani chairs the tax department. Counsel James Gadwood joined from Sullivan & Cromwell LLP in 2016.

Eversheds Sutherland (US) LLP has a ‘renowned practice’ with expertise spanning international, federal, state and local tax law. The team represents Comcast in various tax controversy issues, including in litigation linked to the costs-of-performance apportionment method and disallowance of interest deductions, and a dispute defeating a state’s attempt to impose a tax on Comcast’s intangible property. Cox Enterprises retained the team for several matters, including two successful corporation franchise tax settlements. Jerome Libin and Mark Smith in Washington DC co-head the team. Atlanta-based lawyers Thomas Cullinan, Eric Tresh and Jerold Cohen, who has a ‘longstanding reputation’, are also noted. Bradley Seltzer joined from Deloitte Tax in 2016.

The ‘client-friendlyBaker Botts L.L.P. has a ‘very effective’ tax controversy and litigation practice that acts for various entities in the energy and technology fields in complex disputes, regularly working on federal as well as SALT matters. It also represents taxpayers in estate, gift and transfer tax controversies with the IRS. The team presented the oral argument in MoneyGram’s appeal to the Fifth Circuit regarding a Tax Court decision that it was not a bank for the purposes of sections 581 and 582 of the US Tax Code. Group head Richard Husseini is based in Houston and has ‘excellent understanding of the appeals process’. Also based in Houston is the noted Renn Neilson.

Fenwick & West LLP’s ‘impressive’ California-based team often acts for corporates in tax litigation, representing clients in the US Tax Court, the Court of Federal Claims, and various courts of appeals. The firm is also noted for its ‘strong’ transfer pricing expertise. The ‘first-rate’ David Forst is the firm’s tax chair and the ‘experienced’ Kenneth Clark leads the tax litigation practice, where notable individuals also include Jim Fuller, Jennifer Fuller, Andrew Kim and Larissa Neumann, who has a ‘growing reputation’. Consulting attorney Ron Schrotenboer is also recommended.

Kirkland & Ellis LLP’s ‘extensive’ tax controversy practice is particularly noted for its transfer pricing prowess. The firm has extensive experience in the airline industry and is representing Delta Air Lines in a dispute with the Regional Transportation Authority regarding sales and use taxes on jet fuel. The team is also is the lead tax adviser in numerous major bankruptcies and restructurings. Clients include Energy Future Holdings, Corus Bankshares, GFGI Liquidation Trust and BPCP Dispatch Holdings. Chicago-based partners Natalie Keller, Todd Maynes and JoAnne Nagjee are the key names.

Morrison & Foerster LLP’s ‘outstanding’, dedicated SALT practice is based out of New York and California, but has a nationwide reach. New York-based Mitchell Newmark and Craig Fields (a ‘very accomplished litigator’) led Lorillard Licensing Company in the New Jersey Supreme Court, which upheld the Appellate Division’s decision that New Jersey may not apply dual nexus standards for throwout purposes. Netflix, Agilent Technologies and Astoria Financial Corporation are also clients. New York-based Hollis Hyans and San Francisco-based Andres Vallejo are also recommended. The firm’s federal tax practice handles cases before the IRS, the Tax Court, the Federal Claims Court, and other federal trial and appellate courts, where of counsel Edward Froelich in Washington DC is recommended. In New York, senior counsel Paul Frankel is also singled out for praise. Gregory Roberts joined Reed Smith LLP in 2017.

Norton Rose Fulbright US LLP provides ‘an excellent client experience’ and the team has an ‘encyclopedic understanding of the law’. It advises on multi-jurisdictional competent authority disputes, audits, IRS appeals, summons enforcement, and state and local property tax disputes. The team represented the Allbritton family estate in a tax refund suit against the IRS regarding the valuation of art, and is also acting for Bluescape Resources in an IRS dispute. Diamond Offshore Drilling, Noble Corporation and Baker Hughes are also on the firm’s client roster. In Houston, Charles Hall is ‘very experienced’, Jasper Taylor is ‘clear, concise’ and ‘extremely organized’, and Robert Morris is ‘fantastic’. Chuck Hurley recently joined the firm’s Washington DC office from Mayer Brown.

Reed Smith LLP has ‘vast’ state tax controversy expertise and is also noted for its experience in federal matters. The 13-partner team spans seven US offices and recently obtained a multimillion-dollar cash refund for Dick’s Sporting Goods after a sales tax dispute. The team also assisted the Unclaimed Property Professionals Organization with urging the Supreme Court to hear a dispute between Delaware, Pennsylvania and Wisconsin regarding unclaimed property law. FedEx Corporation, General Motors Corporation and Wells Fargo Bank are also clients. In Philadelphia, Lee Zoeller heads the team, where Frank Gallo and Kyle Sollie are recommended for state tax matters. Gregory Roberts recently joined the New York office from Morrison & Foerster LLP.

Steptoe & Johnson LLP’s ‘excellent’ department is led by Robert Rizzi and Lisa Zarlenga from Washington DC. The team advises on contentious state and federal matters and recently achieved a victory for Delphi Automotive in securing an IRS Office of Appeals determination that Delphi is a UK company, reversing a prior IRS determination that Delphi should be treated as a US company; the firm acted as co-counsel alongside Sidley Austin LLP. The team is also advising Gannett Corporation in a case involving a matter of first impression in Arizona, addressing the scope and application of Arizona’s sales tax deduction for sales of machinery and equipment used directly in manufacturing. Key individuals Greg Kidder, Phil West, Rob Kovacev and Walker Johnson are also based in Washington DC, while Pat Derdenger is based in Phoenix.

Thompson & Knight LLP’s experience spans IRS audits, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation, as well as disputes concerning foreign companies. The team is noted for its strong footing in the petroleum, hard minerals and natural resources sectors and acts as special counsel to Energy Future Holdings in a range of tax-related matters. It also advises Texaco on two cases docketed in the Court of Federal Claims. Dallas-based Mary McNulty (who is ‘very highly regarded’) and Emily Parker are key figures in the practice.

Cooley LLP’s ‘well-respected’ contentious tax practice handles federal, state and international tax disputes, and is led by senior counsel Stephen Gardner from New York. The team has litigated in the US Tax Court, the Court of Federal Claims and in other federal and state jurisdictions, and has handled tax appeals in federal circuit courts. Tax co-chair Kathleen Pakenham is ‘brilliant’. Todd Gluth in San Diego is also recommended.

The timing and quality is outstanding’ at Covington + Burling LLP, where the tax controversy practice is led by Washington DC-based Daniel Luchsinger. The team is advising Boston Bruins on a matter before the US Tax Court involving the deductibility of meal expenses and acted for Shea Homes before the Ninth Circuit regarding the government’s appeal of Shea Homes’ victory before the Tax Court. Bacardi, Bristol-Myers Squibb, Coty and IBM are also clients. In Washington DC, Lee Kelley, Emin Toro, Jeremy Spector, and Sean Akins, who was recently promoted to partner, are recommended. Starling Marshall, a former trial attorney in the US DOJ’s Tax Division, joined the New York office as special counsel.

DLA Piper LLP (US) delivers ‘an excellent service’ and represents clients in federal, state, local, civil and criminal tax audits, appeals and litigation. It also advises multinational companies on international tax audit issues. Michael Patton in Los Angeles is noted for his transfer pricing expertise and led the US sub and Swiss parent of a transportation and logistics company in its US-Switzerland advance pricing agreement renewal, involving commodity trading. The Bill, Hillary and Chelsea Clinton Foundation is also a client. In New York, Ellis Reemer is praised by clients, as is Kathryn Keneally, who is ‘absolutely top notch.’

The Washington DC-based team at Dentons represents clients in all phases of civil and criminal tax controversy against the IRS. The team successfully represented Cayman National Corporation and its subsidiaries in a DOJ tax investigation. James Mastracchio co-chairs the department alongside Jeffry Erney, who joined the team from Baker & Hostetler LLP in February 2016.

Sidley Austin LLP’s ‘very responsive, highly knowledgeable and practical’ department represents clients in federal and state tax disputes nationwide, and is also recognized for its cross-border expertise. In addition, the team handles internal investigations involving tax issues. Alongside co-counsel Steptoe & Johnson LLP, the team successfully advised UK-domiciled Delphi Automotive in connection with the IRS assertion that it should be treated as a US domestic entity. It is also representing Citigroup in state court litigation regarding Louisiana franchise tax apportionment methodology. Matthew Lerner in Washington DC, and senior counsel Jay Zimbler in Chicago head the team.

The ‘very responsive’ group at Sullivan & Cromwell LLP houses ‘expert and experienced partners’ and also draws on the wider experience of its litigation group. The team is involved in all levels of dispute resolution, from the audit level and IRS appeals to court litigation, and is acting for Ferrari and Fiat Chrysler Automobiles in an ongoing EU state aid investigation. EFH Official Committee, Foundry Group and GS Group are also clients. The group is led by Washington DC-based of counsel Donald Korb, who has ‘longstanding experience’, and New York-based Ronald Creamer. James Gadwood recently joined Miller & Chevalier Chartered.

Winston & Strawn LLP’s expertise spans federal, state and local tax matters. The team advises Elan Pharmaceuticals in various states in several cases of first impression involving a number of high-profile biotech industry issues, and acts for Schlumberger Technology in an income tax appeal before the Alaska Supreme Court. Tax chair Amit Kalra is based in the Chicago office, as are Jim Lynch and Lou Weber. The ‘exceptional’ Charles Moll in San Francisco leads the SALT practice.

Based across its New York and Washington DC offices, the ‘well-versed’ team at Davis Polk & Wardwell LLP handles a range of tax controversy matters, including litigation, administrative proceedings, alternative dispute resolution and risk management, and its client-base includes names such as PepsiCo. Department head Mario Verdolini has a ‘fantastic reputation for contentious tax matters’.

Greenberg Traurig, LLP’s nine-strong tax audits and litigation department is well versed in federal, state and local tax disputes. The team delivers advice on sensitive audits, tax compliance and reporting, compromising tax debts, reporting positions, employment tax issues and contested tax refunds. In New York, the ‘well-respected’ Barbara Kaplan heads the team, and Charles Simmons and Scott Fink are also recommended.

Hogan Lovells US LLP handles contentious matters before the IRS, the state tax authorities and various courts. It also acts for domestic and international clients in tax audits and appeals. The firm has particular expertise in tax-exempt organizations. Clients include Open Networking Foundation, Rural Telephone Finance Corporation and Aflac. Team head Siobhan Rausch is based in Washington DC, where Christine Lane was recently promoted to partner and Todd Miller is also recommended. In New York, Howard Topaz and Scott Friedman are other noteworthy names.

Pillsbury Winthrop Shaw Pittman LLP successfully represented a high-net-worth individual in a major California personal income tax case at the California State Board of Equalization and advised two major multinational corporations in a long-running California corporate income tax dispute with the Franchise Tax Board. Amazon, Apple and BNP Paribas are also clients. In San Francisco, Jeffrey Vesely is head of the SALT group, while William Bonano heads the firm’s federal tax controversy and tax policy practice. James Chudy in New York heads the global tax team. Eileen O’Connor left to establish her own firm.

Vinson & Elkins LLP’s tax controversy practice is led by Houston-based George Gerachis and the team has a firm footing advising energy sector clients, as well as clients involved in technology, transport, financial services and other areas. Its expertise spans matters including international tax, state and local tax, the Internal Revenue Code, tax treaties, accounting methods, partnerships, tax credits and valuation issues. In recent work, the firm advised Energy Transfer Partners in a case in Delaware Chancery Court over its merger agreement with the Williams Companies.

The ‘talented’ transfer pricing and tax controversy practice at White & Case LLP is primarily focused on domestic and international civil tax disputes, but also covers criminal tax matters. The team regularly appears before the IRS on behalf of taxpayers in a broad array of disputes. In Washington DC, Kim Boylan is global tax head and Brian Gleicher is noted for transfer pricing and tax treaty issues.

US taxes: non-contentious

Index of tables

  1. US taxes: non-contentious
  2. US - TDH500
  3. Next generation lawyers

US - TDH500

  1. 1
    • Neil Barr - Davis Polk & Wardwell LLP
    • James Barry - Mayer Brown
    • Hatef Behnia - Gibson, Dunn & Crutcher LLP
    • William Bowers - Norton Rose Fulbright US LLP
    • Richard Bronstein - Paul, Weiss, Rifkind, Wharton & Garrison LLP
    • Ronald Creamer - Sullivan & Cromwell LLP
    • Stuart Finkelstein - Skadden, Arps, Slate, Meagher & Flom LLP
    • David Forst - Fenwick & West LLP
    • Gary Friedman - Debevoise & Plimpton LLP
    • James Fuller - Fenwick & West LLP
    • Stuart Goldring - Weil, Gotshal & Manges LLP
    • Stephen Gordon - Cravath, Swaine & Moore LLP
    • David Hariton - Sullivan & Cromwell LLP
    • John Hart - Simpson Thacher & Bartlett LLP
    • Kenneth Heitner - Weil, Gotshal & Manges LLP
    • Alan Kaden - Fried, Frank, Harris, Shriver & Jacobson LLP
    • Alexander Lee - Paul Hastings LLP
    • William Levy - Kirkland & Ellis LLP
    • Todd Maynes - Kirkland & Ellis LLP
    • David Miller - Proskauer Rose LLP
    • Luc Moritz - O’Melveny & Myers LLP
    • Andrew Needham - Cravath, Swaine & Moore LLP
    • Erika Nijenhuis - Cleary Gottlieb Steen & Hamilton LLP
    • Deborah Paul - Wachtell, Lipton, Rosen & Katz
    • James Peaslee - Cleary Gottlieb Steen & Hamilton LLP
    • David Schnabel - Davis Polk & Wardwell LLP
    • Jodi Schwartz - Wachtell, Lipton, Rosen & Katz
    • Eric Sensenbrenner - Skadden, Arps, Slate, Meagher & Flom LLP
    • Avishai Shachar - Davis Polk & Wardwell LLP
    • David Shapiro - Fried, Frank, Harris, Shriver & Jacobson LLP
    • David Sicular - Paul, Weiss, Rifkind, Wharton & Garrison LLP
    • Sharp Sorensen - Sidley Austin LLP
    • Linda Swartz - Cadwalader, Wickersham & Taft LLP
    • Kirt Switzer - Latham & Watkins LLP
    • Samuel Weiner - Latham & Watkins LLP
    • Lowell Yoder - McDermott Will & Emery LLP
    • Pardis Zomorodi - Latham & Watkins LLP

Next generation lawyers

  1. 1
    • Michael Bolotin - Debevoise & Plimpton LLP
    • Christian Brause - Sidley Austin LLP
    • Mike Carew - Kirkland & Ellis LLP
    • Gregory Gallagher - Kirkland & Ellis LLP
    • Monique Gallego - Sidley Austin LLP
    • Jonathan Goldstein - Simpson Thacher & Bartlett LLP
    • Patrick Karsnitz - Paul, Weiss, Rifkind, Wharton & Garrison LLP
    • Lee Morlock - Mayer Brown
    • Chayim Neubort - Weil, Gotshal & Manges LLP
    • Brad Okun - Paul, Weiss, Rifkind, Wharton & Garrison LLP
    • Andrea Ramezan-Jackson - Latham & Watkins LLP
    • Mark Schwed - Weil, Gotshal & Manges LLP
    • Reid Thompson - Fried, Frank, Harris, Shriver & Jacobson LLP
    • Eric Wang - Sullivan & Cromwell LLP
    • Edward Wei - Cadwalader, Wickersham & Taft LLP

Cleary Gottlieb Steen & Hamilton LLP is ‘among the top tax practices globally’, and is a ‘leading name’ for non-contentious tax matters. Its international practice commands respect for successfully combining technical knowledge with clients’ objectives. James Duncan led the team advising SABMiller on the tax matters related to its merger with AB InBev, while Diana Wollman assisted industrial gas producer and supplier Air Liquide with the tax aspects of its $13.4bn acquisition of Airgas. In another key mandate, a team led by William McRae advised the underwriters on the tax implications of Teva Pharmaceutical Industries’ debt offerings, which raised approximately $21bn to finance its acquisition of Allergan. Other notable clients include Citigroup, J.P. Morgan, Morgan Stanley and Goldman Sachs. Leslie Samuels, Yaron Reich, Erika Nijenhuis and James Peaslee are also recommended. All lawyers mentioned are based in New York.

A top firm’, Cravath, Swaine & Moore LLP fields ‘a savvy team of lawyers’ that combines ‘knowledge of the finer points of law with pragmatic solutions’. The team, which has particular expertise in M&A, joint ventures, spin-offs, restructuring and securities, is providing tax advice to AB InBev on an asset swap with Ambev, which involves the transfer of SABMiller’s business in Panama to Ambev and Ambev’s transfer of its business in Colombia, Peru and Ecuador to AB Inbev. Stephen Gordon, Lauren Angelilli and Christopher Fargo led the team on that matter, while Leonard Teti is advising Avon on tax matters connected to its $605m strategic partnership with Cerberus Capital Management and Andrew Needham is assisting British American Tobacco with its $93bn proposed merger with Reynolds American. Other key clients include Amblin Partners, DreamWorks Animation, Unilever, Johnson & Johnson and Honeywell International.

Spread across its offices in New York, Menlo Park and Washington DC, the ‘spectacular’ tax practice at Davis Polk & Wardwell LLP is regularly called on to advise on the most prominent US and international transactions. Highlights included acting for Baker Hughes on its $32bn combination with GE’s oil and gas business, assisting Syngenta with a $43bn offer by ChemChina to acquire the company and advising Markit Group Holdings on its merger with HIS. Aetna, AstraZeneca, ExxonMobil, PepsiCo and Roche are also clients. Neil Barr in Washington DC and New York-based Avishai Shachar head the practice, which includes the ‘very knowledgeable’ David Schnabel, Michael Mollerus and Po Sit.

For many, Kirkland & Ellis LLP is the ‘go-to firm for complex deals locally and internationally’, thanks in part to its ‘proven track record in the tax arena and reliable global capabilities’. Working closely with the transactional department, 2016 proved to be yet another highly active year for the non-contentious tax practice, especially in the energy and oil and gas fields. In an illustration of the practice’s ability to leverage the firm’s market-leading restructuring capability, Todd Maynes, Gregory Gallagher and Sara Zablotney led advice to Energy Future Holdings and 70 of its affiliates on the tax aspects of their Chapter 11 applications, which have involved more than $40bn in debt. In another highlight, Dean Shulman and Mike Carew led the tax advice for Baxalta Incorporated during its $32bn merger with Shire, while Shulman, Carew and Benjamin Schreiner acted for Molson Coors Brewing on its purchase of a 58% stake in SABMiller from AB InBev. The firm also assisted the same client with its sale of a 58% stake in MillerCoors (SABMiller’s and Molson Coors’ joint venture in the US) to AB InBev for approximately $12bn.

Latham & Watkins LLP’s lawyers attract praise for ‘their appropriate advice and reliability’ and ability to provide ‘creative tax structuring for heavy deals including cross-border merger and acquisition transactions’. The tax practice, which is regularly involved in some of the most noteworthy M&A deals particularly in the technology, pharmaceutical and healthcare areas, advised FMC Technologies on the $13bn purchase of Technip, a complex cross-border transaction that spanned three jurisdictions. The firm also provided tax advice to Sirona Dental Systems on its merger with DENTSPLY International and assisted Leonard Green & Partners with multiple corporate acquisitions, which involved a range of partnership tax issues, tax-free sponsors and management rollover. Other clients include BC Partners, Rentech Nitrogen Partners, The Carlyle Group and Lane Industries. Kirt Switzer, Pardis Zomorodi, Samuel Weiner, David Raab, Diana Doyle and David Kahn are all key members of the practice.

Paul, Weiss, Rifkind, Wharton & Garrison LLP’s lawyers are ‘significant players in the development of innovative tax solutions’ and are known for ‘creating appropriate structures to maximize the achievement of responsible tax advantages for clients’. In an illustration of the firm’s ability to devise unique approaches to complex tax issues, Brad Okun and Richard Bronstein are leading the team advising Texas Competitive Electric on its Chapter 11 bankruptcy, which involves a tax-free G reorganization with embedded taxable transactions. Transactional tax highlights included Jeffrey Samuels’ advice to Time Warner Cable on the tax structuring aspects of the client’s $78.7bn merger with Charter Communications. Okun and Patrick Karsnitz were the leading names advising Apollo Global Management in tax matters connected to several associated fund corporations with a matter value well above $15bn. In a different mandate, the group acted for Cable & Wireless Communication in relation to its acquisition of Liberty Global in a $7.4bn operation. Other key clients include General Atlantic, Oaktree Capital, VICE Media and TowerBrook Capital. David Sicular and David Mayo are also recommended.

Simpson Thacher & Bartlett LLP’s tax practice has earned a name for advising on transactional tax mandates encompassing corporate finance, group planning, real estate, M&A and capital markets. Based in New York, ‘pragmatic and technical’ practice head John Hart acted for Hilton on the spin-off of its time share business and hotels into a corporation and REIT, respectively. In other key mandates, Palo Alto-based Katharine Moir led advice to KKR & Co on tax issues arising from its $345m SEC-registered Series A offering; Rob Holo in New York acted for China National Chemical Corporation on the tax aspects of its $43bn acquisition of Syngenta; and Nancy Mehlman (also based in New York) assisted Blackstone with its $8bn purchase of BioMed Realty Trust. Marcy Geller, Gary Mandel and Jonathan Goldstein (all based in New York) are also key members of the practice.

Skadden, Arps, Slate, Meagher & Flom LLP’s 33-lawyer team brings years of experience in both the private and public sectors and a leading presence in cross-border, high-value transactional tax mandates. The group assisted Citigroup with tax issues arising from several high-profile transactions throughout 2016, including the sale of its pre-paid card services business to Wirecard. Other highlights included advising Darden Restaurants on the spin-off of real estate assets into a REIT and assisting Pfizer with its aborted $160bn merger with Allergan, which would have been the largest tax inversion deal on record. Stuart Finkelstein, Eric Sensenbrenner, David Rievman, Pamela Lawrence Endreny and David Polster are all highly recommended.

Sullivan & Cromwell LLP’s tax practice is well known for providing sophisticated, client-oriented advice on complex, cross-border transactions. New York-based Ronald Creamer led advice to Advance/Newhouse Partnership on the merger of its subsidiary Bright House Networks with Charter Communications and Time Warner Cable, creating a company with an equity value in excess of $80bn. Creamer also acted alongside Eric Wang for AB InBev on the tax aspects of its £71bn acquisition of SABMiller. Other clients include ACE Limited, Bayer AG, SIFMA and Enbridge. David Hariton, Andrew Mason and Jeff Hochberg are all noted.

Wachtell, Lipton, Rosen & Katz’s practice regularly handles the tax aspects of corporate reorganizations, acquisitions, spin-offs, financings, restructurings and joint ventures. Jodi Schwartz assisted Century Link with its $34bn acquisition of Level 3 Communications, which included the assumption of pre-existing debt, and advised Monsanto on its $66bn acquisition by Bayer. Other highlights included Deborah Paul’s advice to Supervalu on its $1.4bn sale of Save-A-Lot to Onex Partners and Harman International Industries on its $8.8bn acquisition by Samsung Electronics; Eiko Stange’s advice to Regency Centers on its $15.6bn merger with Equity One; and Joshua Holmes’s advice to TD Ameritrade on its $4bn acquisition of Scottrade.

Weil, Gotshal & Manges LLP’s leading tax practice attracts praise for its ‘top levels of expertise’ and ‘exceptional service; partners demonstrate knowledge of how to apply the law and its implications on business operations’. Kenneth Heitner and Chayim Neubort (who is noted for his ‘exceptionally deep expertise’) advised The Dow Chemical Company on all tax aspects of its $130bn merger with DuPont, while the ‘technical and knowledgeable’ Stuart Goldring assisted Oracle Corporation with the tax aspects of its $9.3bn acquisition of NetSuite and Mark Schwed acted for HNA Group on its $6.5bn acquisition of a 25% stake in Hilton Worldwide Holdings. Other clients include Brookfield Asset Management, Sanofi and Verizon.

Cadwalader, Wickersham & Taft LLP’s ‘premier tax practice’ attracts praise for its innovative approach to tax-efficient structures, as well as for its transactional tax advice. Linda Swartz acted as tax counsel for Procter & Gamble during the $11.4bn merger of its specialty beauty business with Coty, and worked alongside Edward Wei for The Medicines Company during the $792m sale of three of its cardiovascular products to Italian corporation Chiesi Farmaceutici. The firm has also represented global manufacturer The Dover Corporation on the reorganization and sale of Texas Hydraulics to Chicago-based private equity firm Wynnchurch Capital. Other clients include Ashford Hospitality Prime and J.P. Morgan.

Debevoise & Plimpton LLP’s ‘excellent’ tax team, which is jointly headed by the ‘outstanding, proactive and thoughtful’ Peter Schuur and Peter Furci, is commended for its ‘responsiveness, commitment and creative approach to clients’ objectives’ and for its ‘capacity to explain complicated issues in plain English’. Furci led a team advising Verizon Communications on its acquisitions of Telogis and the fibre-optic business of XO Communications. Other highlights for the group included acting for the majority shareholders of Cablevision during its sale to Altice and assisting Envision Healthcare with the tax issues arising from its $15bn merger with Amsurg Corp. Gary Friedman, Robert Staffaroni, Michael Bolotin and Burt Rosen are also recommended.

Fried, Frank, Harris, Shriver & Jacobson LLP’s tax team is ‘excellent; its response time is rapid and its orderly approach means answers are well thought out’. The 11-partner team is headed by Robert Cassanos in New York and Washington DC-based Alan Kaden, and is highly active in tax matters connected to M&A, fund formation, real estate, private equity and restructuring. Highlights included acting for Genesys on its $1.4bn acquisition of Interactive Intelligence Group, and assisting the same client with a $900m investment into the company by affiliates of Hellman & Friedman. Cassanos led advice to Coach on the sale of its interests in the Hudson Yard development. Michael Alter, Henry Lebowitz, David Shapiro and associate Reid Thompson are also recommended. Other clients include Ascential, Goldman Sachs, Terex Corporation and Permira Advisers.

Mayer Brown’s tax group advises on an array of tax-related issues including corporate, partnership and individual taxation with special emphasis on cross-border matters. Highlights included advising Prologis on its $5.9bn acquisition of the real estate assets and operating platform of KTR Capital Partners and its affiliates, and assisting Altice with its acquisition of NYSE-listed Cablevision. Chicago-based partners Lee Morlock and Steve Garden led advice to Yum! Brands on the tax implications of a spin-off to create two independent corporations. Canadian Imperial Bank, TransCanada Corporation and Prologis are also among the firm’s clients. Chicago-based James Barry and Jason Bazar in New York are both respected practitioners.

McDermott Will & Emery LLP fields a large team of dedicated tax lawyers that attracts praise for its ‘high-quality tax advice’. The firm has a track record of advising multinationals and banks on complex tax arrangements governing M&A transactions, financings, joint ventures and restructurings. Key clients include Johnson & Johnson, which the firm advises on tax planning matters related to its global operations, and Exelon, which it advises on tax issues connected to numerous power-related matters including the development of large-scale renewable energy projects, acquisitions, divestitures and others. S&P Global, athenahealth and PGA Tour are also among its clients. Located in Chicago, Lowell Yoder leads the federal and international tax practice, while Jane Wells May heads the state and local tax department. Mark Horowitz, Mark Martin, Robert Clary and Damon Lyon are also noted.

Norton Rose Fulbright US LLP’s highly experienced tax team is particularly noted for its energy sector expertise for clients including Texas Municipal Gas Corporation, which it advised on a program to provide its clients with gas supplies for the purposes of energy production. In another energy-related highlight, it assisted a consortium led by Axium Infrastructure with acquiring a minority stake in a 1,029MW wind portfolio from EDP Renewables North America, which involved devising a tax-efficient structure. On the infrastructure side, a team led by David Gillespie acted for Plenary Group and its affiliates on tax issues related to the development and financing of a PPP project with the City of Long Beach and the Board of Harbour Commissioners. Other clients include Vega Energy Partners and Tesoro Logistics. The US tax practice is led by Robert Phillpott in Houston and includes Andrius Kontrimas who heads the tax practice globally. Stephen Kuntz, Michael Flamenbaum and William Caudill are also key figures.

Paul Hastings LLP’s practice is particularly active on cross-border matters spanning Asia, Latin America and Europe. Recent mandates include advising Takeda Pharmaceutical and healthcare investment firms Bay City Capital and Deerfield Management on the tax aspects of the launch of drug discovery company Bridge Medicines; Andrew Short advised on that matter and leads the team, which includes Alexander Lee, who played a key tax advisory role for Dick Clark Productions during its $1bn sale to Dalian Wanda Group. Other highlights included advising Elanco US and its subsidiary Eli Lilly and Company on the tax aspects of its $885m acquisition of Boehringer Ingelheim Vetmedica’s US feline, canine and rabies vaccines portfolio.

Shearman & Sterling LLP’s multi-disciplinary tax group is reputed for its ability to develop tax-efficient structures for acquisitions, disposals, joint ventures and financings. Ethan Harris led advice to General Electric (GE) on the merger of GE’s oil and gas business with Baker Hughes to create a leading oilfield technology provider with $32bn in combined revenue. In another highlight Laurence Bambino, who jointly leads the practice with Michael Shulman from the firm’s New York office, advised B/E Aerospace on its $6.4bn acquisition by Rockwell Collins. Clients also include American Axle & Manufacturing Holdings, Legg Mason and Francisco Partners. Larry Crouch is also noted.

Sidley Austin LLP has established a reputation for ‘sound, pragmatic and commercial advice’, which the practice provides to multinational corporations on cross-border M&A and securities offerings. Highlights included providing tax advice to Range Resources on its $4.4bn acquisition of gas producer Memorial Resource Development and assisting Stonepeak Infrastructure with the tax aspects of its investments in Targa Resources Corp, Sanchez Energy and Plain All American Pipeline, with an aggregate value in excess of $850m. Other clients include Athene Holding, Citigroup, Deutsche Bank and GE Capital. Laura Barzilai, Robert Kreitman, Edwin Norris, Sharp Sorensen, Christian Brause and Monique Gallego are all recommended.

White & Case LLP’s tax practice attracts praise for its ‘solid experience’ and ‘appropriate and sensible solutions’, which it provides to clients in the energy, media communications and private equity sectors. In a notable mandate William Dantzler, who heads the tax practice for the Americas, led a team advising Anthem on tax issues related to its $54.2bn acquisition of Cigna Corporation. The team also assisted Qingdao Haier with its $5.4bn acquisition of General Electric’s appliance business, GE Appliances, which was the third-largest acquisition of a US company by a Chinese investor at the time of publication. Other notable clients include Fortis, Saudi Refining, Zimmer Biomet and Element Financial. Washington-based Kim Boylan has been appointed global head of the tax practice, which includes David Dreier, Ray Simon, Sang Ji, Brian Gleicher and James Hayden.

Baker McKenzie LLP is well known for its ability to advise multinational corporations on local and international tax matters, including state and local tax (SALT) and e-business taxation, as well as tax matters arising from public transactions, major internal restructurings and post-acquisition integrations. Highlights included advising Abbott Laboratories on tax matters related to its $25bn acquisition of St Jude Medical, assisting Cardtronics with tax issues connected to its re-domiciliation to the UK and advising Expedia on tax planning, M&A and transfer pricing matters. Mary Bennett, Jonathan Martin and Thomas May are all noted.

At Clifford Chance, practice head Richard Catalano led the advice to Apollo Global Management on tax issues arising from the mergers of Apollo Commercial Real Estate Finance and Apollo Residential Mortgage. Other highlights for Catalano included acting as lead counsel for Colony American Homes on its $7.7bn merger with Starwood Waypoint Residential Trust, creating a REIT with over 30,000 homes on its portfolio, while David Moldenhauer and Philip Wagman acted for the shareholders of AB InBev on the tax aspects of the company’s acquisition of SABMiller.

Fenwick & West LLP’s Silicon Valley-based tax practice regularly acts for corporates in the TMT sector and attracts praise for ‘the tremendous insight it brings to dealing with the IRS’. In an illustration of the firm’s excellent M&A pipeline, in 2016 the tax team advised longstanding client Symantec on its $7.4bn sale of Veritas to the Carlyle Group and GIC, and assisted Activision Blizzard with its $5.9bn acquisition of King Digital Entertainment. Key figures include James Fuller and the ‘very knowledgeable’ David Forst, who is ‘an excellent person to partner with’.

Morrison & Foerster LLP’s tax group, which regularly acts for local and international clientele on structuring and implementing taxable and tax-free acquisitions and disposals, is rated for its ‘solid expertise in developing and implementing comprehensive and innovative solutions’. Bernie Pistillo led the advice to Boyd Gaming on the $900m sale of a 50% interest in Marina District Development Holding Company. Pistillo is also advising VMware on Dell’s $67bn acquisition of the client’s parent company EMC Corporation, and acted alongside David Strong and Joy MacIntyre for SoftBank on tax issues related to its internal restructuring as well as on various cross-border sales and purchases. Strong jointly heads the practice with Craig Fields and Thomas Humphreys. Remmelt Reigersman is also noted.

International corporations, financial institutions and private equity funds regularly instruct O’Melveny & Myers LLP on an array of transactions, from corporate formations to complex M&A, particularly where those transactions are considered tax-sensitive or involve emerging tax issues. Highlights included advising LaGuardia Gateway Partnership on the complex tax structure connected to its successful bid to reconstruct La Guardia airport in New York and assisting Alaska Air Group with its $4bn acquisition of Virgin America. California-based partners Robert Blashek, Robert Fisher and Luc Moritz are recommended, as is Arthur Hazlitt in New York.

Orrick, Herrington & Sutcliffe LLP’s client roster includes financial institutions Morgan Stanley, Barclays, BlackRock, Citibank and J.P. Morgan. The practice has established a reputation for advising on fund formation, capital markets and M&A related tax matters; on the capital market front, it advised Credit Suisse on tax issues related to its structured note program. In another highlight, the firm advised Purdue Research Foundation on the tax treatment of income sharing agreements through the client’s new program aimed at providing finance to students’ higher education. Chas Cardall leads the team.

Proskauer Rose LLP’s experienced tax group advises on all areas of corporate and financial tax and specializes in matters related to REITs and fund formation. Recent work includes acting for Pacific Exploration & Production on its acquisition of The Catalyst Group (its former creditor) as part of a cross-border restructuring that included a capital infusion of $240m, a new financing line of $240m and a $115m letter of credit facility. In another notable mandate, the firm advised American Realty Capital, Retail Centers of America and American Finance Trust on their $1.4bn merger. Other clients include Icahn Enterprises, National Hockey League and Lexington Partners. David Miller, Amanda Nussbaum, Ira Bogner, Jamiel Poindexter and Ali Fawaz are all key members of the practice, as is Anne Kim, who receives praise for her ‘patience, knowledge, insightfulness and responsiveness’.

Steptoe & Johnson LLP’s ‘very helpful’ tax lawyers attract praise for their ‘sophisticated’ approach to complex tax issues and are frequently involved in some of the most challenging cases. In an illustration of the firm’s track record in cross-border tax matters, the firm is providing ongoing advice to a US corporation on transfer pricing agreements and tax issues connected to a China business trust. The practice is also advising several clients on tax policy issues before congress and the Treasury, including advice on the impact of legislative and regulatory developments. Robert Rizzi and Lisa Zarlenga lead the team.

Andrews Kurth Kenyon LLP’s practice is known for its expertise in tax-related matters in the oil and gas field and its lawyers are commended for their ‘solution-focused approach and pragmatic advice’. The firm is advising oil and gas exploration and production company Warren Resources on tax matters related to its proposed capital restructuring and advised FourPoint Energy on its acquisition of Chesapeake Energy’s remaining Western Anadarko Basin oil and gas assets. Other key clients include Archer Well Company, Sunoco LP and Six Flags. The practice is led by Houston-based Thomas Ford and includes Robert McNamara, Thomas Popplewell, Allison Mantor and Angela Richards.

DLA Piper LLP (US)’s tax practice works very closely with the firm’s corporate and real estate departments to handle the tax aspects of M&A, private equity and real estate transactions for clients including Qualcomm Incorporated, Windpoint Partners, Juniper Networks and Kadmon Holdings. Sang King, Gerald Rokoff and Stacy Paz lead the ‘very reliable group’, which advised e-commerce giant Groupon on tax issues related to its $782m sale of a controlling stake in LS Korea and Ticket Monster. In another highlight, it provided tax advice to NuVasive on its $410m acquisition of Ellipse Technologies.

Eversheds Sutherland (US) LLP, which was formed in 2017 from the merger of Eversheds LLP and Sutherland Asbill & Brennan LLP, has an active tax practice that acts on domestic and cross-border mandates and attracts praise for its ‘combination of expertise in an array of regulated sectors with global standard tax counsel’. The team, which is led from Washington DC by of counsel practice chair Jerome Libin and practice head Mark Smith, is advising a global corporation on the structuring of its investments in the energy sector and advised Coca-Cola Enterprises on its merger with Coca-Cola European Partners.

Gibson, Dunn & Crutcher LLP’s tax team advised St Jude Medical on its sale to Abbott Laboratories and acted for CVC Capital Partners and Canada Pension Plan Investment Board on their joint acquisition of Petco Animal Supplies for approximately $4.6bn. Arthur Pasternak and Jeffrey Trinklein lead the practice, which includes Romina Weiss, Scott Knutson and Paul Issler.

Hughes Hubbard & Reed LLP fields a tax group that ‘punches above its weight’, and acts for a range of clients including chemical corporations, airliners, leasing companies and investment funds. A team led by Alexander Anderson advised Republic Airways on tax issues connected to its Chapter 11 restructuring, while Andrew Braiterman led advice to Cenveo on the $105m sale of its folded carton and litho-laminated display packaging business to WestRock Company. Chiltern, Smithfield, Epic Pharma and Cipla are also clients.

Milbank, Tweed, Hadley & McCloy LLP’s ‘knowledgeable and responsive’ tax department works closely with the firm’s other practices to handle the tax aspects of asset finance, project finance, M&A and restructuring and insolvency transactions. Highlights included advising Sprint Corporation on the $20bn securitization of FCC spectrum licenses and assisting Zuffa LLC with the $4bn sale of the Ultimate Fighting Championships. Rusell Kestembaum led the team advising Revlon on its acquisition of outstanding shares of Elizabeth Arden. Andrew Walker, Leah Karlov, Manan Shah, Joel Krasnow and Michael Duff are also recommended.

George Hani heads the team at Miller & Chevalier Chartered, which advises on a broad array of tax matters including transfer pricing. The firm acted for leading insurance company Assured Guaranty on its $450m acquisition of CIFG Holding. David Zimmerman is also a key member.

Morgan, Lewis & Bockius LLP has a ‘sophisticated, responsive and commercial’ tax practice, with its lawyers attracting praise for their ‘excellent legal minds’. It acts for a diverse range of clients on public and private M&A, joint ventures and capital markets transactions with particular emphasis on the energy and life science arenas. Recent work includes advising Energy Transfer Partners on the tax implications of its aborted merger with Williams Companies and acting for NextEra Energy on the tax planning aspects of its issuance of common shares. In another mandate, the team is advising Aramark on tax planning issues arising from its $140m acquisition of National Parking Corp. The practice is led by Barton Bassett in Silicon Valley and Joshua Brady in Washington DC.

Jointly led by Alan Waldenberg and Shlomo Twerski, Schulte Roth & Zabel LLP’s tax practice attracts praise for its ‘quick responses to clients’ queries and its deep knowledge of the hedge fund industry’. In a high-profile matter, Waldenberg and Noah Beck led the advice to Albertsons and Cerberus Capital Management on the $9.2bn merger of Safeway. Another highlight saw Waldenberg, Twerski and Philippe Benedict lead the team acting for Marathon Asset Management when Blackstone Strategic Capital Holdings acquired a minority interest in Marathon.

Sullivan & Worcester LLP’s ‘efficient tax group’ is recognized for its work on REIT structuring for clients including data company Equinix, Iron Mountain and American Tower Corporation. It acted as special REIT adviser to the principal investors of Ovation Acquisition on its planned purchase of a utility transmission and distribution business from Energy Future Holdings. David Nagle jointly heads the practice with Ameek Ashok Ponda, who is praised for his technical knowledge.

Thompson & Knight LLPprovides outstanding tax services; the team is particularly adept at tax issues affecting the oil and gas industry’. Attracting praise for its ‘technical knowledge and ability to understand clients’ needs’, the group advised American Midstream Partners on its $302m merger with JP Energy Partners and assisted Yates Petroleum Corporation with tax issues related to its $2.4bn merger with EOG Resources. EnCap Investments and Nexen Petroleum are also clients. John Cohn leads the practice, which includes Todd Lowther, Roger Aksamit and Joe Rudberg.

Winston & Strawn LLP’s 30-lawyer tax practice handles all aspects of tax law and its lawyers have vast expertise acting for large public and private corporations. Louis Weber led the team advising Heritage Food Service on the $260m acquisition of Canadian corporation Choquette CKS and its subsidiary Gestion PSL. In another highlight, Chicago-based practice head Amit Kalra advised Invenergy on the sale of a 823MW portfolio of wind farm assets to TerraForm Power for $1bn. Other key figures include Charles Moll in San Francisco, who heads the state and local tax practice and is a ‘great strategist and courtroom lawyer’. Andrew Ratts in Chicago and New York-based partners Edmund Cohen and Mitch Moetell are also recommended.

Arnold & Porter Kaye Scholer LLP, which was formed from the merger of Arnold & Porter LLP and Kaye Scholer LLP in 2016, fields a team that is well versed in the formation of REITs and non-profit and charitable organizations. Joseph Howe led the team acting as REIT counsel for Welltower on the $1.15bn acquisition of a portfolio of properties from Vintage Senior Living. The firm also provides day-to-day tax advice to The Oakland Raiders and acts as longstanding external tax counsel to the United Nations Foundation. James Joseph, Stuart Lipton, Thomas Richardson, Benjamin Berk and Bridget Weiss are all key members of the team.

Baker Botts L.L.P.’s tax group is ‘very responsive to clients’ initial enquiries and provides timely analysis and feedback based on a great understanding of tax law and the client’s business’. Its tax expertise spans a variety of sectors with particular emphasis on the technology and energy areas. 2016 highlights included advising Schlumberger on tax issues emerging from its $14.8bn merger with Cameron International Corporation and acting for Halliburton on the tax aspects of its aborted merger with Baker Hughes. Derek Green and Don Lonczak lead the practice. Liberty Media Corporation, Starz and AT&T Corp are also clients.

Chadbourne & Parke LLP’s tax advice regularly acts for major public corporations, investment fund managers and financial institutions. Headline mandates included advising NextEra Energy on its purchase of Energy Future Holdings, which is currently involved in the largest bankruptcy proceedings to date, and advising Nomad Holdings on tax issues arising from its $2.8bn reverse acquisition of Iglo Group. Other clients include NRG/Edison Mission, Purdue Pharma, Macquarie and J.P. Morgan. William Cavanagh, Erez Tucner and Keith Martin are key members of the team.

Covington & Burling LLP’s tax practice acts for multinational corporations and private equity funds in tax issues arising from M&A activity, joint ventures, capital markets transactions and internal restructurings. Dan Luchsinger led the US tax advice to Weyerhaeuser REIT on its merger with Plum Creek REIT, which involved the application of of rules concerning REITs and taxable REIT subsidiaries. It also acted for Allergan on the US income tax aspects of the $40bn sale of its generics business to TEVA Pharmaceutical Industries. Sam Maruca, Robert Culbertson, Michael Caballero and Susan Leahy are also recommended.

Dechert LLP’s tax practice is led by New York-based Daniel Dunn, who advised GIC on jointly acquiring (together with Silver Lake Partners) a substantial equity stake in Ancestry for $2.6bn. In another key mandate, Michael Rufkahr led the team advising Bank of America and others in relation to the securitization of a commercial mortgage loan secured by the related borrower’s fee and leasehold interest in a Class A office tower in Boston.

Hogan Lovells US LLP’s tax team is commended for its expertise in real estate and REITs, M&A, capital markets and investment funds. Highlights included acting for Dell on the $3bn sale of its information technology services business to NTT Data Corp and assisting American Homes 4 Rent with its merger with American Residential Properties. Washington DC-based partners Scott Lilienthal and Howard Silver led advice to Vanderbilt University on the spinoff of its medical center business into a new separate entity.

Jones Day attracts praise for its ‘high-quality tax advice, very reasonable fees’ and ‘ability to anticipate the Treasury’s and IRS’s view on specific tax cases’; ‘all in all the team is professional, extremely knowledgeable and a pleasure to work with’. The firm has acted as tax counsel for Abbott Laboratories on numerous acquisitions and disposals, including its purchase of St Jude Medical, and advises Celgene Corporation on tax issues arising from its acquisitions and post-acquisition integration. Joseph Goldman and Edward Kennedy lead the practice.

Highlights for Kramer Levin Naftalis & Frankel LLP’s tax practice included acting for the first-lien noteholders during Caesars Entertainment Operating’s bankruptcy, which involved negotiating tax-free distributions to creditors. In another matter, the firm advised an online provider of regulatory compliance and third-party management services on the sale of an interest in the corporation to a private equity company. The practice is also known for advising high-profile entertainment and sporting figures on tax structuring issues. The eight-lawyer team is headed by Howard Rothman and includes the ‘responsive’ María Jones and Barry Herzog.

The ‘respected’ tax group at Linklaters LLP advises on complex, cross-border transactions, regularly handling US and international tax issues arising from M&A, private equity, investment fund, capital markets and real estate transactions. Andrew Morris and Margot Schonholtz are leading the advice to Wells Fargo Bank (the administrative agent) on a $700m credit line to Atlas Resources Partners. The practice advised the same client on the tax implications of the bankruptcy proceedings of Sabine Oil & Gas. Key figures also include team head Gordon Warnke, Jasper Howard and David Brockway.

Ropes & Gray LLP advises local and international clients on the full range of domestic and international tax issues, including tax planning, structuring cross-border transactions, and tax-exempt transactions. David Saltzman led the team advising Shire Plc on its $32bn agreement to incorporate global pharmaceutical corporation Baxalta. Other highlights included advising Par Pharmaceutical Holdings on tax issues related to its agreement to be absorbed by Ireland-based Endo International. Kaisa Group, TPG Capital and Hutchison China MediTech are also clients. Elaine Murphy and Rom Watson are other names to note.

Working hand-in-hand with the firm’s corporate department, Seyfarth Shaw LLP’s tax lawyers have considerable experience advising real estate developers, investors, investment funds, REITs and joint ventures on tax matters related to their business activities. In a notable mandate, the firm acted for Workspace Property Trust on its $1bn acquisition of 108 office properties located in four states, which involved a tax-efficient structure. The practice is also advising Acadia Realty Trust on all tax matters related to its REIT activities. Steven Meier in Chicago and John Napoli are the key names.

Vinson & Elkins LLP’s Houston-based tax group handles complex transactions for local and international clients, including handling SALT tax planning and employee benefits. In keeping with the firm’s energy-sector expertise, highlights included advising Devon Energy on the tax aspects of its $1.9bn acquisition of land in the Anadarko Basin area from Felix Energy, as well as the acquisition of 253,000 net acres in the Powder River Basin for $600m. In a related transaction, it advised the same client on the tax implications of EnLink Midstream’s $1.55bn acquisition of Tall Oak Midstream. Other clients include Antero Midstream, Apollo Global, Big Star Oil & Gas and Occidental Petroleum Company. George Gerachis and John Lynch lead the practice.

Baker & Hostetler LLP’s standalone tax team can draw on its lawyers’ experience in public posts, to provide comprehensive tax advice on local and state tax issues governing private wealth, non-profit organizations, executive compensations and transactions. In a key matter, it advised a longstanding multinational client on tax issues related to the purchase of a corporation. Paul Schmidt leads the group and is ably supported by John Bates and Jay Nanavati.

Bracewell LLP’s tax lawyers regularly act on high-end transactions for public and private corporations and have particular expertise in the energy industry. In a notable mandate, Elizabeth McGinley and Michele Alexander led the advice to Great Plains on its $12.2bn acquisition of Westar Energy. In another highlight, the firm acted for Venoco and its affiliates on Chapter 11 bankruptcy proceedings, which involved restructuring their debt obligations and capital structure. Gregory Bopp and Lance Behnke are also noted. Abraham Reshtick and Robert Jacobson have joined Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. and Willkie Farr & Gallagher LLP, respectively.

Buchanan Ingersoll & Rooney’s team handles tax matters at the state, local and federal level for a variety of non-profits, in addition to handling cross-border tax issues. Past work has included acting for TV One, a joint venture between Radio One and Comcast, on employee benefits, partnership tax and securities matters. Michael Horowitz and Bruce Booken are key members of the practice.

Choate, Hall & Stewart has a small but ‘efficient’ tax group that ‘gets deals done smoothly’, with special focus on the private equity sector. In a recent highlight, Christian Atwood led the advice to Windjammer Capital Investors on the $750m sale of Protective Industries. The firm also acted for Spectrum Equity on the tax aspects of its acquisition of a healthcare information and market research company. Practice head Louis Marett is also noted.

Cooley LLP has established a firm reputation for providing tax advice to clients in the biopharmaceutical, technology, energy, telecoms and real estate sectors, covering a range of issues, from SALT matters to tax structuring and investment. Highlights included advising Digital Companies on its $246m sale to Alpha Media and assisting Battery Ventures with the $329m sale of Industrial Safety Technologies to Tyco International. Palo Alto-based Mark Winfeld-Hansen jointly chairs the practice with Kathleen Pakenham in New York. Jeremy Naylor is another name to note.

Dentons services a wide variety of clients, from Fortune 500 multinationals through to start-ups, individuals, partnerships and trusts. Highlights included assisting Spire Capital with its sale of Rainbow Early Education to a private equity fund, which involved a pre-transaction structuring and non-taxable rollover. It also advised Innocoll on several transactions, including equity offerings and its redomiciliation into Ireland by way of a merger. Kansas-based Bruce Davidson and Thomas Stephens in Chicago lead the practice.

Under the leadership of Neil Sandford and working in close cooperation the firm’s corporate, private equity, real estate, capital markets and financial services practices, Goodwin’s tax practice attracts praise for its ‘exceptional knowledge of tax planning and transactional structuring’. Howard Cubell led the advice to TA Associates on a variety of local and international operations, including its $1.2bn acquisition of Frank Russell Company’s asset management business from the London Stock Exchange, while Edward Glazer was pivotal in advising The Macerich Company on the tax structuring of its joint ventures with GIC and Heitman to invest in eight malls across the US.

Irell & Manella LLP has a longstanding reputation in the tax arena, where it handles federal, state, local and international tax matters. A team led by of counsel Elliot Freier worked for Dalian Wanda Group on its $3.5bn purchase of Legendary Entertainment, which was one of the largest Chinese cross-border acquisitions to date. The firm also advised Acano on its $700m purchase by Cisco. Other clients include Brookfield Asset Management, Genstar Capital and ConstructConnect.

Ivins, Phillips & Barker is known for its advice on estate planning, corporate tax and employee benefits. Washington DC-based managing partner Eric Fox leads the practice and has extensive expertise in corporate and international tax issues. Rosina Barker left the practice to join Morgan, Lewis & Bockius LLP.

Katten Muchin Rosenman LLP’s ‘pragmatic tax practice’ is noted for its strength in tax structuring M&A, private equity, venture capital and REITs transactions. Practice head Saul Rudo played a key role advising Sterling Partners on its $925m acquisition of GSI Commerce as part of a consortium of investors, which involved acting as primary counsel on the capital raise for the purchase and negotiating management agreements with the management team of eBay Enterprise. Other clients include Aspen Capital and Meritas. Chicago-based Valentina Famparska and Anna-Liza Harris are also recommended.

Loeb & Loeb LLP’s practice, which is jointly headed by Leah Bishop in Los Angeles and Bruce Wexler in New York, has developed a strong reputation among non-profit and tax-exempt organizations, charities, estates and high-net-worth individuals. Bishop specializes in charitable giving and tax-exempt organizations and Wexler is an expert in trusts and estates.

Morris, Manning & Martin, LLP’s practice covers all aspects of tax, with particular expertise in business tax issues and planning for technology companies and other emerging and growth businesses; tax issues governing REITs; and executive compensation matters. Highlights included advising Carl Gregory Enterprises on the sale of 13 auto dealerships to AutoNation and advising Bridge2Solutions (B2S) on tax issues and capital structure implications relating to a $35m investment by Updata Partners. The team is headed by Charles Beaudrot and Timothy Pollock.

Munger, Tolles & Olson is rated for its M&A, real estate, private equity and restructuring expertise. Past highlights have included advising Berkshire Hathaway on its acquisition of Precision Castpart and acting for Air Lease Corporation on a $2.8bn capital raise and $928m IPO. Other clients have included MGM Resorts International and DreamWorks Animation SKG. Robert Dell Angelo, Samuel Greenberg and David Goldman, all based in Los Angeles, are key members of the practice.

Pillsbury Winthrop Shaw Pittman, LLP’s tax group advises a range of clients, including those in the energy, pharmaceuticals, transportation and media spaces, on a variety of local, international and state tax matters. The firm is acting for a large government-owned Swiss bank and its private banking subsidiary on the Department of Justice’s Program for Non-Prosecution Agreements (Non-Target Letters for Swiss Banks) aimed at resolving potential criminal liabilities by these institutions in the US. It also acted for NTT DATA International (TSE) on tax matters connected to its purchase of Dell’s IT division. James Chudy leads the practice, which includes Julie Divola, who counts Amazon among her clients. Jeff Vesely and William Bonano are also key figures.

New York-based boutique Roberts & Holland advises on a wide range of tax issues such as SALT, employee benefits, executive compensation and restructuring for a range of clients including local and foreign publicly traded corporations, investment banks, insurance companies and pension funds. Corporate tax specialist Stuart Gross and Lary Wolf are the key figures.

Stroock & Stroock & Lavan LLP’s tax department is well versed in handling transactional tax matters covering M&A, private equity, bankruptcy and restructuring, and REITs. Head of department Jeffrey Uffner led a team advising J.P. Morgan Asset Management on structuring a tax-driven investment SPV to allow local and an international investors to acquire a 98% interest in a REIT. In another highlight, Mayer Greenberg assisted Carr Properties with a $525m syndicated construction loan to redevelop the former Washington Post site. Other notable names include Micah Bloomfield and Jonathan Kusko. All lawyers mentioned are based in New York.

Willkie Farr & Gallagher LLP’s multi-disciplinary tax team works closely with the firm’s other departments to provide tax structuring and risk allocation advice to local and international clients. In a notable mandate, the practice advised banking and payments technology solutions provider FIS on its $9.1bn acquisition of financial software company SunGard and assisted Assurant with tax issues arising from the $940m sale of its employee benefits business to Sun Life Assurance. The firm also acted for Schroders Investment Management North America on tax structuring and regulatory issues concerning the formation of an insurance-linked securities fund enabling US and Canadian investors to access collateralized reinsurance and other forms of insurance risk. James Brown and Christopher Peters lead the practice.

WilmerHale’s lawyers are recognized for their expertise in tax aspects related to M&A, financings, investments, joint ventures and restructurings. Under the leadership of Kimberly Wethly and ably supported by Richard Andersen, Robert Burke, William Caporizzo and Julie Hogan Rodgers, the practice has established a strong reputation advising life sciences companies and tax-exempt organizations; highlights included assisting Akamai Technologies with the tax aspects of its acquisition of Soha Systems and advising Corvia Medical on a warrant agreement with a life sciences corporation giving the corporation the option to acquire Corvia in the future. Other clients include Analog Devices, Bank of New York Mellon Corporation, Dean Foods Company and Staples.

Ashurst LLP’s tax team attracts praise for its ‘excellent response times and industry knowledge’. David Nirenberg, who leads the practice, specializes in taxation connected to municipal finance, structured bonds and other forms of structured finance products and cross-border/cross-state structuring. Steven Kropp ‘is personable and responsive to clients’ needs’. Clients include GSO Capital Partners, Deutsche Bank, Wells Fargo, J.P. Morgan, Royal Bank of Scotland and BNP Paribas.

Brown Rudnick LLP’s New York-based tax team provides a range of tax planning services, including tax-efficient restructurings and bankruptcy-related reorganizations. Highlights included advising international pharmaceuticals company Midatech Pharma on tax structuring issues related to its acquisition of NASDAQ-listed DARA BioScience, and assisting Lupin, a multinational pharmaceutical corporation headquartered in Mumbai, on its $880m acquisition of GAVIS Pharmaceuticals. Vincent Guglielmotti leads the practice.

Curtis, Mallet-Prevost, Colt & Mosle LLP houses ‘an excellent international tax practice’ under the leadership of Alan Berlin. Marco Blanco ‘tackles the most complex jurisdictional problems calmly and with both technical expertise and creativity’. The firm regularly acts for US-based and foreign clients on complex transactional and international tax matters, including Bank of America Merrill Lynch, which it advises on a day-to-day basis and with any new initiatives relating to restructuring new products and their tax implications.

Gardere Wynne Sewell has extensive experience advising international and local corporations on tax structuring and planning and is regularly involved in complex cross-border matters. The tax group assisted Drill-Quip on tax issues arising from its acquisition of TIW Corporation for $143m. James Howard leads the practice.

Greenberg Traurig, LLP provides comprehensive tax-efficient advice on domestic and cross-border acquisitions as well as on the establishment of US entities and the structuring of joint ventures. The firm also provides assistance to local and international sponsors and managers of domestic and foreign investment funds. Based in New York, the ‘very experienced’ Mary Voce chairs the practice and is ably supported by Seth Entin and federal income tax expert Ozzie Schindler. Robert Simon and Kenneth Zuckerbrot are also key members of the group.

Jenner & Block LLP’s tax practice attracts praise for its ‘high levels of sophisticated advice’ and ‘heavy partner involvement in all mandates’. The firm has particular strength in the food sector; working closely with the corporate department, the tax practice assisted Snyder’s-Lance with its $1.27bn acquisition of Diamond Foods and advised US Foods on tax issues arising from its $1.02bn IPO. Other clients includes Kraft Foods Group, Archer Daniels Midland and Merge Healthcare Incorporated. ‘Strategic thinker’ Geoffrey Davis and Christian Kimball lead the practice.

Jones Walker LLP advises international and local clients on transactional tax, estate planning, state and local tax, employee benefits, ERISA and executive compensation, tax credit programs, and tax policy and regulation. William Backstrom leads the practice and brings more than 30 years of experience in tax issues. Highlights included advising LLOG Exploration Company on tax issues related to an equity investment in oil and gas properties and a negotiated joint development agreement for the operation of those properties with an overall value of $700m. Rudolph Ramelli, Jesse Adams, John Fletcher and Andrew Burvant are all key members of the practice.

Located in Chicago, Neal, Gerber & Eisenberg LLP has a recognized tax practice that provides ‘the qualities of a large firm with the creativity and responsiveness of a mid-size one’. Domestic and international tax and business planning are strengths of the practice, which also advises on state and local taxation and unclaimed property compliance. Its lawyers are well versed with related case evaluations, risk assessments and case developments. Scott Bakal and John Biek jointly lead the practice and are considered ‘experts in the tax arena’; Bakal is noted for his expertise in structuring tax-efficient vehicles for international investors in hedge funds. The team is advising an investment real estate group on US tax implications of investments made by its foreign investors.

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