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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 

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

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

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

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

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

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

 

 

 

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

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

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

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

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

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