World Tax - Home
The comprehensive guide to the world's leading tax firms

Led by Gregg Lemein, Baker & McKenzie's Chicago practice comprises 17 partners and 29 fee earners. While the practice is active in transfer pricing, tax litigation, and state and local tax, it is particularly strong in international corporate tax.The ... [more]

Led by Gregg Lemein, Baker & McKenzie's Chicago practice comprises 17 partners and 29 fee earners. While the practice is active in transfer pricing, tax litigation, and state and local tax, it is particularly strong in international corporate tax.

The firm is highly regarded by peers and clients alike. "US international tax is Baker & McKenzie's sweet spot; they are one of the top firms [in that area]," said one client. "Baker & McKenzie has a great tax controversy practice," one competitor said. "I have tremendous respect for Gregg Lemein's skills, especially in transfer pricing, but in international tax as well," said another. Clients praise Jeff Maydew as an excellent technician. "He's as good as the firm's senior partners in international tax," said one client. Rivals also express respect for Jim O'Brien for his skill in tax controversy and particularly his experience in transfer pricing disputes.

The firm acted as tax counsel to electronics retail chain Best Buy on the restructuring of its joint venture with Carphone Warehouse, the UK mobile telecommunications retailer, and is acting as trial counsel on behalf of Western Union, which is involved in a dispute with the IRS over a tax-free reorganisation that included a cost-sharing agreement. In 2003, Western Union, a subsidiary of First Data at the time, transferred foreign goodwill and going-concern value as part of a restructuring of its foreign-to-foreign money transfer business in a tax-free reorganisation. The company also entered into a cost-sharing arrangement with a foreign affiliate. The IRS denies that any material foreign goodwill and going-concern value was transferred and asserts the value of the compensable intangibles to be $3 billion.

[hide]

As transfer pricing assumes much more importance for US and international tax authorities, Deloitte's Chicago practice, comprising a staff of 116 partners and fee earners, is taking a more holistic approach to how it serves its transfer pricing clients. ... [more]

As transfer pricing assumes much more importance for US and international tax authorities, Deloitte's Chicago practice, comprising a staff of 116 partners and fee earners, is taking a more holistic approach to how it serves its transfer pricing clients. Through its Business Model Optimisation unit, the firm's professionals look at how a business manages its procurement, intellectual property, supply chain and other processes to optimise them for tax purposes. They also work with their consulting group on tax optimisation of post-merger integration, M&A, and supply chain activities. Tom Driscoll leads the international tax, central region practice; Michele McGuire is indirect tax group leader.

[hide]

Ernst & Young's Chicago international tax services practice, led by Simon Moore, is the second largest within the firm. It has seen a significant increase in activity in all areas of the practice, with particular focus in the heavy manufacturing, life ... [more]

Ernst & Young's Chicago international tax services practice, led by Simon Moore, is the second largest within the firm. It has seen a significant increase in activity in all areas of the practice, with particular focus in the heavy manufacturing, life sciences, and high-tech industries. Professionals in the Chicago office focus on international tax planning, tax effective supply chain management (TESCM), international tax compliance and quantitative consulting, international M&A, capital markets, partnership transactions and transfer pricing. The practice added two new partners in the past year. Chad Munz, who has a background in the life sciences industry, joined as a partner in November 2011and Kevin Glen arrived from Citadel. Two principals also joined from other firms and the firm promoted one adviser to the position of principal.

[hide]

Kirkland & Ellis's Chicago practice employs 19 tax partners and seven fee earners. The firm does not have practice or group heads, as such. Jeffrey Sheffield, Todd Maynes, Don Rocap, Natalie Keller and William Welke are the senior partners in the practice. ... [more]

Kirkland & Ellis's Chicago practice employs 19 tax partners and seven fee earners. The firm does not have practice or group heads, as such. Jeffrey Sheffield, Todd Maynes, Don Rocap, Natalie Keller and William Welke are the senior partners in the practice. Competitors praise Jack Levin for his M&A expertise. "He is top notch," said one rival. In June 2011, it added two new partners to its team: Edward Schneidman and William Levy, both partners at Mayer Brown with extensive experience in real estate. Kirkland & Ellis's strongest practice area has been private equity, but they also specialise in energy and real estate. In March 2012, Kirkland advised Constellation Energy Group, a long-time client, on its $7.9-billion merger with Chicago-based energy company Exelon in a stock-for-stock transaction. Kirkland also represented Oklahoma-based Tronox in its $3.4-billion acquisition in June 2012 of the mineral sands operations of Exxaro Resources, a South African coal and iron ore mining company. Exxaro will have a 38.5% stake in the new company, New Tronox, which will be the world's largest fully-integrated producer of titanium ore and titanium dioxide.

[hide]

Mayer Brown maintains its Tier 1 position in the Chicago market thanks to a practice that is dominant in domestic and international tax controversy and tax transactions. During the year, the firm has handled several high-profile cases. Mayer Brown ... [more]

Mayer Brown maintains its Tier 1 position in the Chicago market thanks to a practice that is dominant in domestic and international tax controversy and tax transactions. During the year, the firm has handled several high-profile cases.

Mayer Brown is representing power management company Eaton Corporation, which is challenging the IRS’s decision to cancel two advance pricing agreements the two parties had signed regarding the intercompany sales between 2001 and 2005. The case is being closely watched as it is the first time a court will address the tax authority’s right to cancel an APA. In addition, the litigation will address significant transfer pricing issues, including the methodology to apply in calculating intercompany sale prices.

In the case of ConEdison, Mayer Brown’s team secured a victory for the public utility against the IRS, totalling $200 million in taxes and interest. The victory was particularly significant because this is the first and only lease-in, lease-out case to date in which the court has ruled in the taxpayer’s favour. The case also involved the application of the economic substance and substance-over-form doctrines, which are staple arguments for the government. An appeal is pending in the Federal Circuit.

The firm’s 37-member tax team is led by Joel Williamson and Larry Langdon (tax controversy) and Kenneth Klein and James Barry (tax transactions). The firm lost two partners during the past 12 months with the departure of Patricia Anne Rexford who left in autumn 2011 to join Baker & McKenzie and Greg Barton who joined PwC in July 2011.

[hide]

McDermott Will & Emery has a large tax practice group in Chicago, employing nearly 40 attorneys. It focuses on the tax aspects of large M&A deals, corporate restructurings and high-profile advisory work and is led by Lowell Yoder, head of US and international ... [more]

McDermott Will & Emery has a large tax practice group in Chicago, employing nearly 40 attorneys. It focuses on the tax aspects of large M&A deals, corporate restructurings and high-profile advisory work and is led by Lowell Yoder, head of US and international tax, and Jane Wells May, head of state and local tax. Clients include manufacturing, pharmaceutical and auto companies. The firm is well respected by peers. "It is a very fine Chicago practice," said one competitor. And Yoder is also highly regarded by the market for his cross-border structuring skills. "Lowell Yoder is an expert in international tax. He is a very, very talented lawyer," one competitor said. McDermott substantially strengthened its transfer pricing practice in June 2012 with the addition of highly respected international tax lawyers Cym Lowell and Mark Martin as part of a seven-member team from Gardere Wynne Sewell in Texas. Martin, who will serve as head of the transfer pricing team, will be based in McDermott's Houston office along with partner John Woodruff and an associate. Lowell and three professional advisers – managing director Hiroaki Furuya, economist Tracy Gomes, and financial analyst Haiyan Zhang – will practise out of a satellite office in Dallas. While the team will be based in Texas it will serve McDermott's clients across the US.

McDermott's Chicago team advised mining and construction equipment manufacturer Caterpillar on the tax aspects of its $8.8 billion acquisition of Bucyrus International. The firm is also lead outside counsel for the manufacturer in audits before the IRS. The team also advised Fortune Brands on the the tax-free spin-off of its home and security business into a separate, publicly-traded company. The practice is often called in by companies to advise on complex tax matters that are part of internal and external restructurings, even if the firm is not acting as corporate counsel in the transaction. In July 2012, the firm added two new partners to its tax controversy group. Roger Jones and Andrew Roberson both joined from Latham & Watkins.

[hide]

Led by David Polster, Skadden, Arps, Slate, Meagher & Flom's 21-member tax group in Chicago, advises clients on all tax aspects of federal and state tax planning and dispute work, including transfer pricing, operational tax planning and tax controversy ... [more]

Led by David Polster, Skadden, Arps, Slate, Meagher & Flom's 21-member tax group in Chicago, advises clients on all tax aspects of federal and state tax planning and dispute work, including transfer pricing, operational tax planning and tax controversy matters. The Chicago office's clients include pharmaceutical, financial services and consumer goods companies. In the last year, Skadden Arps's Chicago professionals were part of the firm's tax team that advised Westfield Group on its about-$1-billion joint venture with Starwood Capital; on its formation of a $4.8 billion joint venture with the Canada Pension Plan Investment Board for 12 of Westfield's shopping centres in the US; and on its $612.5 million joint venture with the New York Port Authority for a 50% stake in the World Trade Centre's retail space. Diane Ryan, former national chief of appeals for the IRS, joined the practice as of counsel in August 2011. Tax partner Andrew Kenoe retired in December 2011.

[hide]

"Jenner is one of those hidden nuggets," one client said about Jenner & Block's seven-member tax team, which provides transactional and controversy advice to businesses, tax-exempt organisations and individuals on all aspects of federal, state and local ... [more]

"Jenner is one of those hidden nuggets," one client said about Jenner & Block's seven-member tax team, which provides transactional and controversy advice to businesses, tax-exempt organisations and individuals on all aspects of federal, state and local tax. The tax practice's leader, Christian Kimball, is highly regarded and trusted by clients. "In terms of judgment, he is second to none," said one client who described Kimball as his go-to person on all M&A transactions but also for his judgment on non-M&A issues, such as dealing with the IRS and tax planning. Clients also acknowledge tax partners Steve Meier, Gail Morse and Jeff Davis.

The team's clients come from all sectors of the economy, including aerospace, defence, manufacturing, e-commerce, financial services, and telecommunications. In September 2011, Jenner & Block advised Hertz Global Holdings on its $2.5 billion debt restructuring and on the acquisition of Donlen, a vehicle fleet leasing and management services company. In October 2011, the firm advised the US subsidiary of Swiss chemicals manufacturer Lonza Group on its $1.4 billion acquisition of Arch Chemicals, a US company.

[hide]

Led by Saul Rudo, Katten Muchin Rosenman's is Chicago tax practice has five partners and three fee earners who focus on M&A tax planning, reorganisations, spin-offs, private equity, venture capital and hedge funds, leveraged buy-out transactions, real ... [more]

Led by Saul Rudo, Katten Muchin Rosenman's is Chicago tax practice has five partners and three fee earners who focus on M&A tax planning, reorganisations, spin-offs, private equity, venture capital and hedge funds, leveraged buy-out transactions, real estate funds and other specialised areas. The firm also counsels foreign clients on the tax aspects of their US operations and investments, and advises US clients on the implications of foreign expansion and activities. In October 2011, Katten assisted private equity firm Sterling Partners in the $590 million acquisition of all the outstanding common shares of Mosaid Technologies, a Canadian public company that was the subject of an unsolicited offer from a competitor. The firm represented Sterling Partners in equity co-investments and advised the client on broader aspects of the transaction.

[hide]

Deloitte's Dallas and Houston practices focus on different industries, reflecting the difference between the two markets. The Dallas practice, which has 34 international tax and nine transfer pricing practitioners, is oriented towards the consumer goods ... [more]

Deloitte's Dallas and Houston practices focus on different industries, reflecting the difference between the two markets. The Dallas practice, which has 34 international tax and nine transfer pricing practitioners, is oriented towards the consumer goods sector, especially retail. It is also active, however, in real estate and financial services. The Houston practice, employing 58 international tax and 13 transfer pricing practitioners, is involved in a lot of domestic and foreign energy transactions. Deloitte in Houston provides its clients with services ranging from planning and executing the transaction to helping their clients organise/structure their tax model post-transaction. Brian Pinto heads the international tax practice as Deloitte's mid-America region leader. John Wells is his transfer pricing counterpart. Peers praise Amin Nosrat and Joe Allen for their work in cross-border structuring and Randy Price for his transfer pricing expertise.

[hide]

Ernst & Young's international tax practice in Houston and Dallas, led by Amy Ritchie, is known for its technical ability in reorganisations, M&A, and partnership structuring in the drilling, oilfield services, and exploration and production industries. ... [more]

Ernst & Young's international tax practice in Houston and Dallas, led by Amy Ritchie, is known for its technical ability in reorganisations, M&A, and partnership structuring in the drilling, oilfield services, and exploration and production industries. The firm's transfer pricing practice, led by Mark Camp, has seen an increase in the number of US and global documentation projects they have been asked to do. The practice has done more and more work helping to operationalise clients' transfer pricing function. In other words, make it work better, often through the use of automation to track transfer pricing policies in real time. This in turn, enables taxpayers to make adjustments throughout the tax year rather than wait for transfer pricing data to become available. The cornerstone of this offering is a multidisciplinary approach which incorporates transfer pricing, advisory and tax process analysis. Over the past year, the firm saw three new partners join its international tax group in Houston: Ritchie, who recently became international tax practice leader; Jennifer Cobb who transferred from the New York practice in March 2012; and Kelly Hales who was promoted to partner.

[hide]

Houston-based Fulbright & Jaworski's tax practice, led by Jack Allender, comprises 26 partners and 43 fee earners active in transfer pricing, corporate tax, and tax disputes. In addition to advising their clients, which include companies from the pharmaceutical, ... [more]

Houston-based Fulbright & Jaworski's tax practice, led by Jack Allender, comprises 26 partners and 43 fee earners active in transfer pricing, corporate tax, and tax disputes. In addition to advising their clients, which include companies from the pharmaceutical, health care, and energy sectors, Fulbright's tax practice group also gets a steady stream of referral work from other firms. In December 2011, the practice advised energy company Total E&P USA on its $2.3-billion acquisition of an undivided 25% interest in, and the joint development of, 619,000 net mineral acres of oil and gas properties in the Utica Shale of eastern Ohio from Chesapeake Exploration and affiliates of EnerVest. The transaction also included a joint venture formed by the three entities for the purpose of operating midstream assets related to the oil and gas properties that Chesapeake contributed. The joint venture will also construct and operate other midstream assets to serve such oil and gas properties. Fulbright lost two partners with the departure of Glen Eichelberger, who left in May 2011 to join Bracewell and Giuliani and Nancy Bowen, who retired in April 2012. Senior tax practitioner Charles Hall is highly praised by competitors. "He is one of the greatest tax controversy lawyers ever," a rival said.

[hide]

Vinson & Elkins has increased their number of clients in the technology, financial services, hedge funds, and private equity sectors without losing its leading position as an energy law firm. Its Dallas and Houston practices, led by George Gerachis, ... [more]

Vinson & Elkins has increased their number of clients in the technology, financial services, hedge funds, and private equity sectors without losing its leading position as an energy law firm. Its Dallas and Houston practices, led by George Gerachis, head of tax and employment benefits/executive compensation, employ 21 partners and 29 fee earners, specialising in international tax, transfer pricing and tax disputes. During the past year, Vinson & Elkins represented Consol Energy, Devon Energy, and Pioneer Natural Resources as tax counsel in connection with their joint venture agreements in the shale industry. The transactions, which are valued at more than $6.8 billion, involved the acquisition of substantial interests in US oil and gas properties.

[hide]

Baker & McKenzie's Dallas and Houston practices are sought out for complex multi-jurisdictional tax minimisation, post-acquisition restructuring, redomestications, transfer pricing and supply chain restructuring projects where tax efficiency is the driver ... [more]

Baker & McKenzie's Dallas and Houston practices are sought out for complex multi-jurisdictional tax minimisation, post-acquisition restructuring, redomestications, transfer pricing and supply chain restructuring projects where tax efficiency is the driver for the project, and not an add-on to a predominantly corporate or M&A assignment. The Dallas and Houston offices, led by Robert Albaral and Susan Stone respectively, are also active in complex federal and state tax disputes at various stages, including audit, administrative appeals and judicial proceedings. The firm's Houston practice advised Ensco on the public merger of equals with Pride International, which resulted in the world's second largest drilling company, with a market capitalisation of more than $13 billion. The merger was completed in May 2011, the post-merger restructuring is still unfinished though. As a result of Ensco's 2009 redomestication to the UK, the merger accomplished the de facto redomestication of the Pride Group to the UK. Baker & McKenzie served as US and UK tax counsel from the negotiation stages of the merger agreement through the closing and then for post-merger restructuring.

[hide]

Led by Walt White, Grant Thornton's Dallas/Houston practice comprises two partners and 29 fee earners active in transfer pricing and corporate tax. In August 2011, the firm advised a Canadian public energy company on establishing a Luxembourg finance ... [more]

Led by Walt White, Grant Thornton's Dallas/Houston practice comprises two partners and 29 fee earners active in transfer pricing and corporate tax. In August 2011, the firm advised a Canadian public energy company on establishing a Luxembourg finance subsidiary. The structure took advantage of the Canada – US treaty protocol

[hide]

Locke Lord's Dallas and Houston practices, headed by Chris Allison and employing a staff of 33, serve clients from a variety of sectors, including health care, pharmaceutical, private equity funds, and financial services. The firm represented health ... [more]

Locke Lord's Dallas and Houston practices, headed by Chris Allison and employing a staff of 33, serve clients from a variety of sectors, including health care, pharmaceutical, private equity funds, and financial services. The firm represented health insurer Humana, a US publicly-held company, in its acquisition of all the stock of Concentra in a taxable merger transaction for about $790 million. Locke Lord has also represented eye care product manufacturer Alcon and its affiliates in a series of acquisitions, including the stock of LenSx Lasers for up to $750 million.

[hide]

Jared Rusman heads the tax practice of Weil, Gotshal & Manges in Texas, which specialises in transactional tax and serves international, national and regional clients. In the past year, it has been involved in transactions involving jurisdictions such ... [more]

Jared Rusman heads the tax practice of Weil, Gotshal & Manges in Texas, which specialises in transactional tax and serves international, national and regional clients. In the past year, it has been involved in transactions involving jurisdictions such as China, Brazil, India, Hong Kong, the UK, France and Canada. Their clients come from a range of sectors, such as oil equipment and oilfield services, media, biotechnology and air transport. The firm represented energy company Kinder Morgan in its $38-billion acquisition of El Paso. The Weil team had to fast-track the deal given that El Paso had already announced its plan to spin-off its exploration and production unit. The combined enterprise resulting from the merger and including Kinder Morgan Energy Partners and El Paso Pipeline Partners, the associated master limited partnerships, will represent the largest natural gas pipeline in the US, the largest independent transporter of petroleum products in the US, the largest transporter of CO2 in the US, the largest independent terminal owner/operator in the US and the fourth largest energy company in North America. Weil Gotshal added a new partner in July 2011, hiring Rodney Moore to build the firm's energy practice. Moore, who was previously with Vinson & Elkins, splits his time between Dallas and Houston.

[hide]

During the past year, Alvarez & Marsal – Taxand's Dallas practice, led by Brian Cumberland, compensation and benefits leader, has been involved in numerous large tax projects. The practice has assisted companies with the SEC disclosure requirements related ... [more]

During the past year, Alvarez & Marsal – Taxand's Dallas practice, led by Brian Cumberland, compensation and benefits leader, has been involved in numerous large tax projects. The practice has assisted companies with the SEC disclosure requirements related to executive compensation; with payroll compliance issues including resolution of disputes with regulatory authorities; and with tax and accounting issues related to long-term incentives. In March 2012, the Dallas office acquired a new director with the hiring of Enrique MacGregor, a former managing director at Ceteris, an economics consulting firm specialising in transfer pricing and intellectual property. Jim Eberle, R&D managing director, heads the firm's Houston practice, which over the past year has provided tax controversy assistance to an energy services company; has advised a foreign multinational energy company on tax issues related to a US acquisition; and has assisted an energy-related company with tax matters associated with an equity-raising transaction.

[hide]

Bracewell & Giuliani's tax practice, headed by Elizabeth McGinley, is particularly strong in advising on master limited partnerships, energy, private investment funds, distressed situations/bankruptcy, corporate and international transactions, and financial ... [more]

Bracewell & Giuliani's tax practice, headed by Elizabeth McGinley, is particularly strong in advising on master limited partnerships, energy, private investment funds, distressed situations/bankruptcy, corporate and international transactions, and financial products. Bracewell has advised a number of major international energy companies, including Kinder Morgan and Chesapeake Energy on their tax affairs. During the past year, Bracewell represented ConocoPhillips in the $23- billion spin-off of Phillips 66, which is now an independent downstream energy company with businesses in refining and marketing, midstream and chemicals. The complex transaction required the segregation of assets and joint ventures, negotiation of transactional arrangements and the allocation of each liability – each with major tax implications. Phillips 66 became an independent, publicly-traded company on the New York Stock Exchange on May 1 2012.

[hide]

Deloitte's Los Angeles practice primarily serves middle-market clients – companies with revenues of $800 million-$1.5 billion – in the electronics/high-tech field, gaming and media, distribution and services, and life sciences. However, clients also ... [more]

Deloitte's Los Angeles practice primarily serves middle-market clients – companies with revenues of $800 million-$1.5 billion – in the electronics/high-tech field, gaming and media, distribution and services, and life sciences. However, clients also include a number of Fortune 50 companies as well. Its team of 47 practitioners specialise in international tax, transfer pricing and indirect tax. The international tax group, headed by regional tax managing partner Scott Mund, has seen a lot of inbound activity, particularly from China and India in interactive gaming and entertainment. Repatriation planning – tax-efficient ways of bringing money back to the US from overseas – is also an area of growth as companies try to figure out where the economy is headed. They are also assisting clients with various planning situations in preparation for possible tax reform. The transfer pricing practice, led by transfer pricing west region leader Mark Nehoray, can be broken down into compliance and consulting. Compliance includes documentation, reports that serve as a guide for taxpayers, IRS audits and advance pricing agreements. Dispute resolution and arbitration can also fall under this category. The consulting side includes Business Model Optimisation, supply chain management, licensing arrangements and restructurings. Rivals praise Nehoray for his transfer pricing skills and expertise.

[hide]

DLA Piper's Los Angeles office has the largest international tax practice in the area. It has a particular expertise in post-acquisition integration. As a result, Los Angeles tax leader Michael Lebovitz and senior associate Stephen Weerts are leading ... [more]

DLA Piper's Los Angeles office has the largest international tax practice in the area. It has a particular expertise in post-acquisition integration. As a result, Los Angeles tax leader Michael Lebovitz and senior associate Stephen Weerts are leading a global team of DLA Piper lawyers in the 13-country integration of NCR's $1.6-billion acquisition of Radiant Systems. Atlanta's NCR is one of the leading manufacturers of ATMs and related technologies. Radiant Systems, from Minneapolis, is a global technology company. Many of the issues that need to be addressed in the integration process include corporate, intellectual property and labour issues, but the process is tax-driven. The work is expected to be completed by the end of the year. Lebovitz, has also recently assumed responsibilities in London, splitting his time between the two locations. "Mike Lebovitz and Stephen Weerts are terrific. They are very responsive, very articulate," said one client. "They provide excellent customer support and service." The firm lost Bernhard von Thaden, who left in December 2011 to return to KPMG. However, his departure has not had an impact on the firm as all client relationships remained with DLA Piper.

[hide]

Ernst & Young's Los Angeles practice falls under the firm's West area, which stretches from North to South, creating what the firm has termed "one West." Julieanne Wooldridge, West international tax services leader, heads both the Los Angeles and San ... [more]

Ernst & Young's Los Angeles practice falls under the firm's West area, which stretches from North to South, creating what the firm has termed "one West." Julieanne Wooldridge, West international tax services leader, heads both the Los Angeles and San Francisco practices. The Los Angeles tax practice employs six partners and 36 fee earners specialising in corporate tax and transfer pricing. During the past year, the LA tax team has assisted taxpayers with supply chain restructurings, global structure realignment, post-merger integration, transfer pricing and advance pricing agreements. The practice has also witnessed an uptick in the M&A market in recent months, particularly in private equity. The firm is also particularly strong on the west coast due to its foreign desk network, which enables the firm to offer real-time solutions to companies in China, India, the Netherlands, and Luxembourg. The LA practice acquired a new partner with the promotion of Cynthia Yu in June 2011. Yu is particularly strong on global M&A planning experience in multiple industries. International tax partner Frederick Wooldridge is well respected by tax professionals, who recognise his skill in cross-border structuring.

[hide]

Led by Moshe Kushman, Skadden, Arps, Slate, Meagher & Flom's California tax practice includes the offices in Los Angeles and Palo Alto. Clients include companies from the health care, technology, financial services, and real estate sectors. During the ... [more]

Led by Moshe Kushman, Skadden, Arps, Slate, Meagher & Flom's California tax practice includes the offices in Los Angeles and Palo Alto. Clients include companies from the health care, technology, financial services, and real estate sectors. During the past year, Skadden represented Australia's Centro Properties Group, a real estate investment trust and a developer and manager of shopping malls, on the tax aspects of its $9.4 billion sale via an auction of its US shopping centres to private equity firm The Blackstone Group. In another sizeable transaction, the firm represented Hitachi Global Storage Technologies on the tax aspects of its $4.8 billion acquisition by Western Digital Corporation. Both companies are manufacturers of computer storage drives. Kushman is highly regarded by his peers for his M&A work.

[hide]

Dana Proud Newman is the tax leader of Pillsbury Winthrop Shaw Pittman's Los Angeles practice, which employs 23 partners and 10 fee earners. The firm's California corporate tax attorneys advise multinational companies on their US business ventures, including ... [more]

Dana Proud Newman is the tax leader of Pillsbury Winthrop Shaw Pittman's Los Angeles practice, which employs 23 partners and 10 fee earners. The firm's California corporate tax attorneys advise multinational companies on their US business ventures, including the structuring of their entities, M&A, dispositions and transfer pricing. They also advise US corporations on joint ventures and provide guidance on tax credit investments.

[hide]

Deloitte's team of 189 practitioners in New York is heavily focused on inbound investment, with roughly 20% of its international tax professionals dedicated to this type of client. Jo Ann Catalano is Northeast international tax practice leader and her ... [more]

Deloitte's team of 189 practitioners in New York is heavily focused on inbound investment, with roughly 20% of its international tax professionals dedicated to this type of client. Jo Ann Catalano is Northeast international tax practice leader and her group focuses on M&A structuring and compliance, as well as supply chain planning and IP planning as companies focus more on how they can better align their business and tax strategies in the context of their principal and IP companies. John Kennedy focuses on private equity. His practice covers structuring a fund and a subsequent acquisition. After that, Kennedy and his group tend to do most of the tax compliance that relates to the investment for the duration of the holding period. Deloitte has seen significant growth in private equity, asset management and hedge funds. While all other practice areas are organised regionally, Deloitte's transfer pricing practice is a national group, headed by Todd Wolosoff who also became managing partner of Deloitte's global transfer pricing practice in 2012. In his new role, Wolosoff has implemented several key global strategic initiatives, such as the transfer pricing Industries Program focused on bringing deep industry knowledge and expertise to the firm's clients. Based in New York, Robert Plunkett heads the financial services transfer pricing group. In the past year, the firm advised a diversified communications and media company, in one of the few advance pricing agreements (APAs) to have been negotiated in China. The client was facing significant double taxation, in the tens of millions of dollars, on an annual basis. Deloitte was also the first firm to host a financial services roundtable with the Internal Revenue Service and the UK's tax authority, HM Revenues & Customs. The New York practice acquired a new principal with the hiring of Carlos Schmidt in May 2011, and two transfer pricing professionals, with the relocation of Shanto Ghosh from Deloitte India in October 2011 and Bill Yohana from Deloitte Australia in June 2012.

Deloitte is the sole sponsor of the Organisation for International Investment, a leading lobbying group for inbound companies in Washington DC. Global US investment practice leader Robert Stricof testified before a House Ways and Means subcommittee on inbound matters, making Deloitte the only firm represented in the hearings. It was also represented in hearings on outbound matters, along with several other firms.

[hide]

Led by Craig Hillier, Ernst & Young's New York practice employs more than 230 tax professionals who focus on all aspects of international tax planning, transfer pricing, tax compliance and tax controversy. In the past year, the practice has grown significantly ... [more]

Led by Craig Hillier, Ernst & Young's New York practice employs more than 230 tax professionals who focus on all aspects of international tax planning, transfer pricing, tax compliance and tax controversy. In the past year, the practice has grown significantly through internal partner/principal promotions and lateral hires. For example, the hire of Hae-Young Kim from PwC strengthens Ernst & Young's ability to advise Korean and Japanese inbound multinationals on global and US international tax. And the arrival of Siv Schultz, former head of transfer pricing for Pfizer, as a transfer pricing principal, and the relocation of partners Karen Holden and Cedric Bernardeau, from Ernst & Young's Philadelphia office, is a sign that the practice is increasing its expertise in the life sciences industry.

The firm continues its focus on media and entertainment, emerging technology and the digital industry, given New York's emergence as a technology/social media hub. The financial services national group comprises more than 100 professionals, including international tax, transfer pricing, and foreign desk professionals. Recent additions include Chris Ocasal from Sutherland, Asbill and Brennan as principal. He leads the group's international tax services group for the insurance industry. Alex Gurevich, from PwC, is another transfer pricing partner focused on the broader financial services market.

The firm's foreign desk network employs nearly 100 professionals in New York, representing more than 30 jurisdictions. Michael Merwin, a PhD economist and senior partner, relocated to run the NY non-financial services international tax practice. He previously headed the midwest international tax practice.

[hide]

Skadden, Arps, Slate, Meagher & Flom's New York practice is led by Matthew Rosen, global co-head of the firm's worldwide tax group, and Stuart Finkelstein, leader of the New York tax group. In April 2012, Skadden represented long-time client Pfizer in ... [more]

Skadden, Arps, Slate, Meagher & Flom's New York practice is led by Matthew Rosen, global co-head of the firm's worldwide tax group, and Stuart Finkelstein, leader of the New York tax group. In April 2012, Skadden represented long-time client Pfizer in its about $11.9 billion divestiture of Pfizer Nutrition, a paediatric nutrition company, to Switzerland's Nestlé. Skadden is advising the same client on the proposed spin-off of its animal health business into a separate publicly-traded company via an initial public offering (IPO). The firm is also involved in the Grupo Modelo deal, the largest M&A transaction in Mexico's history, as one of the advisers of Belgian brewer Anheuser-Busch InBev on its $20.1 billion acquisition of the Mexican producer of Corona. The firm also acts for clients to resolve high stakes, complex tax controversies and in the most significant litigated tax cases in the US, both at trial and on appeal. Edward Gonzalez and Kirk Wallace earn peers' recognition for their in-depth knowledge of capital markets and financial products. Rosen and David Rievman are admired for their M&A work.

[hide]

Led by Andrew Solomon, Sullivan & Cromwell's New York practice comprises 12 partners and 45 fee earners active in corporate tax, transfer pricing, and tax disputes. In the last year, the practice has been advising a European company on an IRS transfer ... [more]

Led by Andrew Solomon, Sullivan & Cromwell's New York practice comprises 12 partners and 45 fee earners active in corporate tax, transfer pricing, and tax disputes. In the last year, the practice has been advising a European company on an IRS transfer pricing audit with a particular focus on a cost-sharing arrangement. The case raises interesting issues about whether the cost-sharing arrangement is grandfathered under the pre-2009 cost-sharing regulations and how to apply these regulations to the company's products and business model, which are atypical of the standard types of cost-sharing arrangements governed by US rules. In August 2011, Sullivan & Cromwell advised BHP Billiton, the Anglo-Australian mining company, on its $15.1 billion acquisition of America's Petrohawk Energy. The acquisition was structured as an all-cash tender offer for all the issued and outstanding shares of Petrohawk's common stock. The completion of the tender offer was followed by a second-step, short-form merger. Peers praise Solomon and David Hariton for their expertise in cross-border structuring. Ron Creamer is recognised for his M&A work.

[hide]

Clients respect and trust Debevoise & Plimpton's tax practice. "Debevoise, and Seth Rosen in particular, is our favourite," said one taxpayer. "They deliver what we need: insightful tax legal advice and opinion that are focused and on point. They don't ... [more]

Clients respect and trust Debevoise & Plimpton's tax practice. "Debevoise, and Seth Rosen in particular, is our favourite," said one taxpayer. "They deliver what we need: insightful tax legal advice and opinion that are focused and on point. They don't always say what we want to hear but what we need to hear."

The New York office, which is also the firm's headquarters, has a diverse corporate tax practice, comprising 10 partners in New York, three in major European cities, and 29 fee earners. The companies they represent are from, for example, the media, airline, mining, energy, and real estate industries, but they are particularly strong in financial services and insurance, with clients such as The Prudential Company. In March 2012, the New York practice, led by another Rosen, Burt, advised insurance company AIG on its $6 billion sale of a portion of its controlling stake in AIA Group, a life insurer. In another matter, announced in February 2012, David Schnabel is advising Access Industries, as part of a consortium with Apollo Global Management and Riverstone Holdings, on its $7.15 billion acquisition of the oil and gas exploration and production assets of El Paso, which are being sold in connection with Kinder Morgan's $38-billion acquisition of El Paso. Preqin, the research firm, said this deal is the largest private equity-backed deal so far this year and the second largest deal since the collapse of Lehman Brothers.

[hide]

Shearman & Sterling's New York tax practice serves a variety of industries, including manufacturing, consumer goods and medical equipment, in addition to the financial services sector, in which it has a long-standing tradition. The practice, led by Laurence ... [more]

Shearman & Sterling's New York tax practice serves a variety of industries, including manufacturing, consumer goods and medical equipment, in addition to the financial services sector, in which it has a long-standing tradition. The practice, led by Laurence Bambino and Michael Shulman, who also head the global tax group, comprises seven partners and seven fee earners active in corporate tax and tax controversy. The firm represented Synthes, a leading global manufacturer of orthopaedic devices, in its definitive agreement to be acquired by health care product manufacturer Johnson & Johnson for $21.3 billion in June 2012. The practice also represented ArcelorMittal in the sale of Skyline to Nucor. Skyline Steel is a disregarded entity for US tax purposes and as a result, the $600 million transaction gave rise to a number of local tax issues. Skyline Steel was also a foreign affiliate for Canadian tax purposes, and therefore, various Canadian issues also had to be addressed. Clients speak highly of Bambino and tax partner Doug McFadyen. "Larry Bambino and Doug McFadyen are very different and complement each other," said one client, who having worked with the firm for more than 20 years intends to continue the long working relationship. "Doug is very technical; he's good at delivering the written opinion. Larry is a big picture guy. He is good at simplifying complex concepts to help you understand, making them more palatable. They bring different propositions to the table." Peter Blessing is admired by peers for his skill in cross-border structuring.

[hide]

The New York tax practice of Weil, Gotshal & Manges has 17 partners and 24 fee earners, who work closely with transactional lawyers to give advice on virtually every type of matter that presents significant tax issues. These include complex M&A, private ... [more]

The New York tax practice of Weil, Gotshal & Manges has 17 partners and 24 fee earners, who work closely with transactional lawyers to give advice on virtually every type of matter that presents significant tax issues. These include complex M&A, private equity and private funds, bankruptcy, securitisation, real estate, capital markets and restructuring matters. The practice is led by Kenneth Heitner, Martin Pollack and Scott Sontag, who are also the global tax practice leaders.

Clients describe the firm's lawyers as "excellent and talented". Kimberly Blanchard is well respected by clients and peers for her skill in corporate tax. Marc Silberberg earns praise from competitors for his expertise in corporate tax.

Weil is representing Advent International, together with a private equity unit of Goldman Sachs, on the $3 billion acquisition of credit information provider, TransUnion, from Madison Dearborn Partners and the Pritzker family. The firm has also worked on some high-profile bankruptcies. For example, it represented American Airlines and its parent company AMR, AMR Eagle Holding and certain of their subsidiaries in their chapter 11 bankruptcy proceedings. The transaction is valued at $29.5 billion. The tax group continues to advise Lehman Brothers on the tax elements of the case of its bankruptcy proceedings.

[hide]

Baker & McKenzie's New York tax practice comprises 11 partners and 10 fee earners specialising in international corporate tax, transfer pricing, and state and local tax. Thomas May, who assumed the position of North American tax planning and transactions ... [more]

Baker & McKenzie's New York tax practice comprises 11 partners and 10 fee earners specialising in international corporate tax, transfer pricing, and state and local tax. Thomas May, who assumed the position of North American tax planning and transactions subpractice committee chairman in January 2012, moved to the New York office from Washington DC with the aim of growing the practice. May is co-head of the New York practice together with Robert DeJoy, chairman of the New York tax group. The practice has been advising Ecolab, a NYSE-listed food and beverage processor, on its $8.24 billion merger with water treatment services company Nalco Holding, also listed on the same exchange. May and Jonathan Stevens, as well as Alex Chadwick, corporate tax practice leader in London, were the lead tax advisers to Sony and Mubadala during their bid for and purchase of $2.2 billion of EMI's music publishing unit, which owns more than 1.3 million copyrights. The firm reviewed tax due diligence material to construct a tax-efficient investment structure and also advised on the negotiation of the tax provisions of deal documents in the transaction. Marc Levey is well respected by peers for his transfer pricing expertise.

[hide]

The New York practice of Kirkland & Ellis, which employs nine partners and nine fee earners, is particularly strong in private equity. Greer Phillips, Stephen Fraidin, William Sorabella and David Feirstein are advising Burger King Worldwide Holdings ... [more]

The New York practice of Kirkland & Ellis, which employs nine partners and nine fee earners, is particularly strong in private equity. Greer Phillips, Stephen Fraidin, William Sorabella and David Feirstein are advising Burger King Worldwide Holdings and its controlling stockholder 3G Capital Partners, in a business combination with Justice Holdings, a London Stock Exchange-listed public investment vehicle. The transaction will result in a partial sale of Burger King to Justice shareholders and a NYSE listing of Burger King. Under the terms of the agreement, Burger King will merge with a new Justice entity and be renamed Burger King Worldwide; 3G Capital will receive $1.4 billion in cash and a 71% stake in the new company, which will begin trading on the NYSE at the closing. Former Justice shareholders and its founders will hold the remaining 29% interest. The transaction, which comes 18 months after Kirkland helped 3G Capital take Burger King private in a $4 billion leveraged buy-out, values Burger King at about $1.8 billion. Once the transaction is completed, 3G Capital will have returned all of its investors' invested equity capital from the 2010 deal – as well as additional investment returns – and 3G Capital will continue to own 71% of the company. The transaction also helps Burger King obtain a NYSE listing without the market uncertainty of a conventional IPO process. Kirkland & Ellis does not have formal department heads, but the senior partners in the New York tax practice group are Phillips, Steve Clemens and Patrick Gallagher.

[hide]

Mayer Brown's New York tax group, comprising five partners and 11 fee earners, provides clients with the full range of tax services, but is particularly strong in corporate tax and tax disputes, with most of its advisers working in those areas. Joel ... [more]

Mayer Brown's New York tax group, comprising five partners and 11 fee earners, provides clients with the full range of tax services, but is particularly strong in corporate tax and tax disputes, with most of its advisers working in those areas. Joel Williamson and Larry Langdon head the tax controversy practice, though neither's home office is New York, while Kenneth Klein, who is based in Washington, DC and James Barry, who works in Chicago, lead the tax transactions group. The firm's clients include companies such as Société Générale, Altria Group, and GE. In July 2011, the practice represented private investment firm Kenner & Company in its $590million acquisition of Dynacast, a leading global provider of precision die cast components, from the UK's Melrose. This was a major LBO involving more than 20 countries and nine Mayer Brown offices. In a tax dispute the firm was able to secure a major victory for its client, Consolidated Edison Company, of New York, in the US Court of Federal Claims. The case involved the taxation of a complex leveraged lease transaction – lease-in, lease-out (LILO). The court held that ConEdison had acquired an ownership interest in a power facility in the Netherlands, enabling the power company to claim tax deductions for its ownership interest and for interest incurred to acquire the facility. Then another dispute arose regarding the interest the government owed the taxpayer. The court again ruled in favour of ConEdison, holding that it was allowed to claim the benefits of interest netting in calculating the amount owed to the company by the US. This resulted in an additional refund of more than $6 million bringing the total value of the taxes and interest at stake in the case to $200 million. This is the first LILO case where the court has ruled in favour of the taxpayer. The case also involved the application of the economic substance and substance-over-form doctrines, which are staple arguments for the government. An appeal is pending in the Federal Circuit. Mayer Brown lost two partners from its New York practice, with the departure of Patricia Anne Rexford, who left in autumn 2011 to join Baker & McKenzie; and Greg Barton who left to join PwC in July 2011. Alvan Bobrow is the newest addition to Mayer Brown's New York practice. Previously a partner at Hodgson Russ, he joined the firm in January 2012 as a partner in the tax transactions and consulting group and leader of the national state, and local tax group.

[hide]

Led by William Dantzler, White & Case's New York office is a full-service tax firm dealing with M&A, securities and bankruptcy tax issues. The practice has grown with the addition of eight leading partners from Dewey LeBoeuf after that firm's dissolution ... [more]

Led by William Dantzler, White & Case's New York office is a full-service tax firm dealing with M&A, securities and bankruptcy tax issues. The practice has grown with the addition of eight leading partners from Dewey LeBoeuf after that firm's dissolution in May 2012. The team of M&A lawyers who joined White & Case were led by Mort Pierce, who has more than 30 years of experience, and Denise Cerasani, who also has extensive experience in the areas of securities and corporate finance. The other six partners were Michelle Rutta, Chang-Do Gong, Robert Chung, Bryan Luchs, Brian Smarsh and Gregory Owens. The practice is advising Saudi Arabian Oil (Saudi Aramco), its client of more than 50 years, on tax aspects related to its joint venture with Dow Chemical to build and operate a $20 billion world-scale integrated chemicals complex in Jubail Industrial City in Saudia Arabia. Saudi Aramco and Dow will form Sadara Chemical, a joint venture, which will operate the chemicals complex, one of the largest integrated chemical complexes in the world and the largest to be built in a single phase. In another matter, the firm's New York and Washington DC practices represented a global paint company in an IRS audit of sales of convertible preferred stock by the client to the client's employee stock purchase and savings plan. The IRS proposed income tax adjustments and the imposition of excise taxes of $1.2 billion. White & Case's attorneys provided critical advice to the client during the IRS audit and defended the client's positions in mediation with the tax authority. As a result, the IRS conceded about 90% of its proposed adjustments resulting in the resolution of the case. The practice lost Gerald Rokoff to DLA Piper in June 2011.

[hide]

While Alvarez & Marsal – Taxand is widely known for its expertise in bankruptcy – it has been working with Lehman Brothers Holdings for the past five years as its chief restructuring officer – the firm, including the New York tax practice, provides clients ... [more]

While Alvarez & Marsal – Taxand is widely known for its expertise in bankruptcy – it has been working with Lehman Brothers Holdings for the past five years as its chief restructuring officer – the firm, including the New York tax practice, provides clients with a full range of services: global tax assessments, tax efficient supply chain consulting, transfer pricing studies and planning, state and local tax advice, and controversy work before the IRS and state and local tax authorities. Its clients include a broad spectrum of domestic and international clients, from small, high-tech start-ups and private equity funds to Fortune 500 corporations and financial institutions. During the past year, the New York tax group, led by Robert Lowe, the chief executive officer, assisted life sciences company CR Bard in analysing and evaluating various opportunities to build operational improvements into its global supply chain. It has also worked with the company to identify and mitigate subpart F exposure across their global organisation, and has advised the client with regard to several cross-border planning opportunities. The New York practice gained a new partner with the hiring of James Bartek from PwC, where he was a tax director, in March 2012.

[hide]

Headed by transactional tax chairman Bruce Wein, DLA Piper's New York practice has a varied list of clients in the US and abroad. The group of seven partners and 11 fee earners provides tax and business planning advice and dispute resolution representation ... [more]

Headed by transactional tax chairman Bruce Wein, DLA Piper's New York practice has a varied list of clients in the US and abroad. The group of seven partners and 11 fee earners provides tax and business planning advice and dispute resolution representation on all federal, state and local matters. The team's areas of expertise include real estate taxation, M&A and dispositions, tax disputes, tax policy and legislation, complex international tax, emerging growth and venture capital, investment funds, financial products and estate planning. Gerald Rokoff, who joined the firm from White & Case in 2011, was the lead tax partner in the worldwide tax planning for Arsenal Capital Partners, a leading private equity firm that invests in middle-market specialty industrial, healthcare and financial services companies, in its acquisition of Plasticolor's and Evonik's global colorants business with operations in Germany, Holland, and Australia. This transaction involved more than 100 attorneys in numerous practice areas and locations, including Amsterdam, Frankfurt, Sydney, Mexico City, Beijing, New York and Miami.

[hide]

McDermott Will & Emery's New York office is a full-service tax practice, comprising eight partners and seven fee earners. It advises large companies and financial institutions requiring tax structuring advice, whether in relation to M&A, financing, joint ... [more]

McDermott Will & Emery's New York office is a full-service tax practice, comprising eight partners and seven fee earners. It advises large companies and financial institutions requiring tax structuring advice, whether in relation to M&A, financing, joint ventures or restructuring. While the tax team works closely with its corporate lawyers on transactions, clients seek out McDermott specifically for tax advice and representation. In the past year, the New York practice, led by Thomas Giegerich, advised a trustee on a $24 billion split-off transaction involving international agricultural company Cargill and Mosaic, a leading provider of crop nutrients and feed ingredients. McDermott advised the trustee on the tax aspects of the distribution of Cargill's 64% ownership stake in Mosaic to certain Cargill shareholders and debt holders and on related contractual matters. The firm's clients include American Airlines, AT&T, Bank of America, Goldman Sachs, IBM, NBC Universal, Pfizer and other major corporations. Rivals recognise Peter Faber and Arthur Rosen for their skill in indirect tax.

[hide]

Pillsbury Winthrop Shaw Pittman's New York tax practice, headed by firmwide practice leader James Chudy and New York practice leader Harsha Reddy, is primarily transactional. Its 33-member team advises across a spectrum of tax issues that includes securitisations, ... [more]

Pillsbury Winthrop Shaw Pittman's New York tax practice, headed by firmwide practice leader James Chudy and New York practice leader Harsha Reddy, is primarily transactional. Its 33-member team advises across a spectrum of tax issues that includes securitisations, complex extensions of credit, structured finance, international transaction planning, energy tax credit planning, cross-border finance, inbound and outbound securities offerings, M&A and joint ventures. The practice represented US-based Tenaska Energy in connection with its $476 million development and financing of the Imperial Solar Energy Center South, a 130-megawatt solar project in Imperial County, California, which was financed with construction loans and a cash grant bridge loan provided by a syndicate of mostly non-US banks. This was the largest ever bank financing for a solar energy company in the US.

[hide]

Led by Edward Tanenbaum, Alston & Bird's New York office is predominantly a cross-border tax practice and consists largely of the representation of foreign multinationals and high-net-worth individuals/families with respect to US investments. It handles ... [more]

Led by Edward Tanenbaum, Alston & Bird's New York office is predominantly a cross-border tax practice and consists largely of the representation of foreign multinationals and high-net-worth individuals/families with respect to US investments. It handles dispute resolution matters at all levels of the government and the courts and is involved in all areas of multijurisdictional tax planning and structuring. Its clients include some of the largest Fortune 500 companies operating across multi-state lines. The firm is representing a foreign banking association before the IRS and Treasury on matters affecting withholding taxes and reporting obligations under the Foreign Tax Compliance Act (FATCA) provisions. The representation has been instrumental in providing for more user-friendly compliance requirements that will greatly benefit the association's members without disrupting the capital markets.

[hide]

The three partners and four other tax lawyers in Freshfields Bruckhaus Deringer's New York and Washington DC offices work together as one team, led by Gregory May. The firm advises US and international clients on M&A, capital markets, investment funds, ... [more]

The three partners and four other tax lawyers in Freshfields Bruckhaus Deringer's New York and Washington DC offices work together as one team, led by Gregory May. The firm advises US and international clients on M&A, capital markets, investment funds, derivatives and structured products, finance and corporate tax planning. In February 2012, Freshfields advised The Royal Bank of Scotland, as global coordinator and arranger, and Barclays Capital, HSBC, and Lloyds Bank as the joint lead managers on the $1.9 billion refinancing and development financing solution for holiday villages operator Center Parcs. The financing blended a corporate secured bond (Whole Business Securitisation) with a high-yield bond. The issuance of a high-yield bond out of the same structure as the WBS was the first of its kind in Europe and allowed Center Parcs to maximise its investor base.

[hide]

Headed by Peter Keenan, Torys's New York practice focuses primarily on corporate tax. Its five-member team serves clients in the energy, financial services and real estate sectors. The firm advised commodities producer and trader Glencore International ... [more]

Headed by Peter Keenan, Torys's New York practice focuses primarily on corporate tax. Its five-member team serves clients in the energy, financial services and real estate sectors. The firm advised commodities producer and trader Glencore International in relation to its IPO. Torys provided solutions relating to the pre-IPO reorganisation of the company, including the transformation of a complex capital structure under Swiss law to an ordinary share structure in preparation for flotation on the London and Hong Kong stock exchanges. Torys continues to advise Glencore on related matters. The May 2011 offering was the largest international IPO in the history of the London Stock Exchange. The publicly-traded company has a market capitalisation of $61 billion. In another sizeable transaction, the firm represented Brookfield Renewable Power in the $6.4 billion strategic combination of its renewable power assets with Brookfield Renewable Power Fund. The result was the creation of Brookfield Renewable, one of the largest, publicly-traded, pure-play renewable power platforms globally.

[hide]

Well-established on the west coast, Baker & McKenzie's California practice, which comprises the San Francisco and Palo Alto groups, is highly regarded for its sophisticated international tax advice, tax planning and controversy defence for clients in ... [more]

Well-established on the west coast, Baker & McKenzie's California practice, which comprises the San Francisco and Palo Alto groups, is highly regarded for its sophisticated international tax advice, tax planning and controversy defence for clients in the high-tech and pharmaceuticals industries. In the past year, the practice, led by Palo Alto tax practice group chairman Scott Frewing, had an important taxpayer victory in the case of Veritas Software Corp & Subs, Symantec Corp (successor in interest to Veritas Software) v Commissioner, 133 TC 297 (2009). It was the only cost-sharing buy-in case ever to be tried to final judgment in the Tax Court. In another case, the practice represented Broadcom in its defence against proposed transfer pricing adjustments totalling more than $5 billion for the company's 2001 to 2006 tax years. The primary transfer pricing issues concerned the arm's-length cost-sharing buy-in payments due under Treasury Regulations section 1.482-7 (g) (1995) for pre-existing and acquired intangibles made available to a qualified cost-sharing arrangement. Baker & McKenzie also advised the US communications semiconductor provider on multiple acquisitions in Israel, Spain, the UK and US, and on the integration of these companies into their structure. Competitors praise John Peterson for his work in cross-border structuring. The firm lost Beth Williams to Bingham McCutchen in August 2011. Diana Lathi left the firm in September 2011to join Intuitive Surgical as vice president, corporate tax.

[hide]

Deloitte's San Francisco and San Jose practice offers clients services in international tax, transfer pricing and indirect tax. The two offices employ 88 practitioners, led by Mike Reichert, international tax west region leader; Keith Reams, transfer ... [more]

Deloitte's San Francisco and San Jose practice offers clients services in international tax, transfer pricing and indirect tax. The two offices employ 88 practitioners, led by Mike Reichert, international tax west region leader; Keith Reams, transfer pricing leader for US clients and markets; and Ron Saake. The west region covers Seattle, Las Vegas, California, and Hawaii. In the past year, the San Francisco and San Jose practices have seen greater client demand for advice on supply chain management, in anticipation of US tax law changes, but also in regards to worldwide developments. M&A activity has also been increasing as Silicon Valley companies look for opportunities to grow. The firm has added a new senior partner in the Bay Area with the hiring of Doug Wibbing from Armanino McKenna. Two advisers were promoted to international tax directors, while another became a senior manager in August 2012. Reichert, Saake and Jeff Sokol are well respected by peers for their expertise and skill in the corporate tax practice area. Deloitte lost an international tax director to Alvarez & Marsal – Taxand in March 2012.

[hide]

DLA Piper's San Francisco/Silicon Valley tax practice, led by global and US tax practice chairman David Colker, has seen growth in international tax, tax controversy and transactional tax (M&A), in the past year. In addition to those practice areas, ... [more]

DLA Piper's San Francisco/Silicon Valley tax practice, led by global and US tax practice chairman David Colker, has seen growth in international tax, tax controversy and transactional tax (M&A), in the past year. In addition to those practice areas, the firm also has a strong transfer pricing group and an advance pricing agreement practice, made possible because the practice has its own team of economists. In the past year, DLA Piper was able to favourably resolve an R&D tax credit appeal for a high-tech company whose products were extremely complex. The case involved many significant issues, for example, how to deal with prototypes, since the complexity of the company's products required a lot of working models. The government allowed 98% of the original claim. The case closed in early 2012. In another matter, DLA Piper advised a US high-tech multinational on a global restructuring and was able to lock in the lowest level of income than any other company had achieved, according to the company's accounting firm's advisers, who also worked on the case. The practice promoted two lawyers, Tamara Shepard and Stacy Paz, to the partnership in the past 12 months.

[hide]

Ernst & Young's San Francisco practice falls under the firm's West area which stretches from north to south, creating what the firm has termed "one West." Julieanne Wooldridge, West international tax services (ITS) leader, heads both the Los Angeles ... [more]

Ernst & Young's San Francisco practice falls under the firm's West area which stretches from north to south, creating what the firm has termed "one West." Julieanne Wooldridge, West international tax services (ITS) leader, heads both the Los Angeles and San Francisco practices. The Bay Area practice employs 12 partners and 36 fee earners, with the majority of the practitioners working on corporate tax and transfer pricing. Their practice and the market they operate in is technology focused. Clients include Fortune 10 and Fortune 50 companies. Practice leaders with a focus on international transactions include Stephen Bates, principal national west; Michael Bumbaca, senior partner, ITS/transaction tax; and Beth Carr, tax partner. The Bay Area practice's transfer pricing leaders include Brian Cromwell, transfer pricing principal; Lonnie Brist, transfer pricing principal and PhD economist; and Curt Kinsky, principal and west sub-area transfer pricing leader.

[hide]

West coast-based Fenwick & West's tax practice, led by David Forst, employs nine partners and 16 associates. They provide clients – among them major Fortune 500 companies – with services in tax advice/tax planning, transfer pricing and tax controversy. ... [more]

West coast-based Fenwick & West's tax practice, led by David Forst, employs nine partners and 16 associates. They provide clients – among them major Fortune 500 companies – with services in tax advice/tax planning, transfer pricing and tax controversy. In April 2012, the firm advised Facebook on its $550 million acquisition of about 650 AOL patents recently acquired by Microsoft. In another high-profile transaction for the social media network, also in April, Fenwick & West served as their external corporate and tax counsel in the $1billion acquisition of mobile photo-sharing start-up Instagram. The tax team also often advises clients in transactions where their corporate colleagues are not involved. In tax controversy, Fenwick & West has resolved nearly 20 large corporate cases at the IRS appeals level during the past year.

[hide]

Mayer Brown's Palo Alto practice, comprising three partners - Larry Langdon, Paul DiSangro and Cabell Chinnis -  and three fee earners, is active in transfer pricing, corporate tax and tax disputes. The firm's tax controversy practice has grown over ... [more]

Mayer Brown's Palo Alto practice, comprising three partners - Larry Langdon, Paul DiSangro and Cabell Chinnis -  and three fee earners, is active in transfer pricing, corporate tax and tax disputes. The firm's tax controversy practice has grown over the past year in volume and significance, with its partners and associates handling several IRS appeals matters involving several hundred millions of dollars in proposed adjustments. Mayer Brown also has a docketed case in the US Tax Court involving a high-profile taxpayer with a precedent-making cost-sharing issue. Another high-profile case the practice is involved in is representing diversified power management company Eaton Corporation in litigation pending in the Tax Court regarding the IRS's cancellation of two advance pricing agreements it had signed with the taxpayer. The IRS has asserted tax deficiencies for 2005 and 2006 related to Eaton's transfer pricing of products manufactured in its Puerto Rican and Dominican Republic facilities and sold to Eaton's US subsidiaries. The litigation will be the first time in which a court will address the IRS's right to cancel an APA. In addition, the litigation will address significant transfer pricing issues, including the methodology to apply in calculating intercompany sale prices. [hide]

McDermott Will & Emery's Silicon Valley practice, led by Frederick Chilton, offers clients range and depth in corporate tax planning, state and local tax, tax controversy and litigation. A large percentage of the practice's clients are from the technology ... [more]

McDermott Will & Emery's Silicon Valley practice, led by Frederick Chilton, offers clients range and depth in corporate tax planning, state and local tax, tax controversy and litigation. A large percentage of the practice's clients are from the technology sector in northern California. This year, the firm has also increased its number of clients based outside Silicon Valley. In the federal tax area, the firm has been involved in a variety of outbound and inbound transactions. Because of the Silicon Valley group's focus on the technology sector, the firm has extensive experience in intellectual property-related tax issues, such as the formation of intangible holding companies. Rod Donnelly joined Morgan, Lewis & Bockius in October 2011.

[hide]

Morgan Lewis & Bockius's northern California practice, led by Gary Wilcox, provides planning, tax controversy and litigation services in the areas of corporate tax, international tax, transfer pricing, state and local tax, M&A, and employee benefits ... [more]

Morgan Lewis & Bockius's northern California practice, led by Gary Wilcox, provides planning, tax controversy and litigation services in the areas of corporate tax, international tax, transfer pricing, state and local tax, M&A, and employee benefits and executive compensation.

Clients praise the firm's quality of work, as well as international tax partner Bart Bassett. "Morgan Lewis helped with a state tax audit, eliminating a sizeable assessment within a matter of weeks," said one client, who switched firms when Bassett moved to the firm.

During the past year, attorneys from the group's 13-member team have represented a US public company in a multi-billion dollar transfer pricing issue that is now before IRS Appeals. The practice also served as tax counsel to a US public company concerning efforts to advocate for US international tax reform. The firm's advice covered technical aspects of reform proposals and crafting responses and proposed changes. In October 2011, Rod Donnelly joined the firm as a transfer pricing partner. He was previously a partner at McDermott Will & Emery.

[hide]

Alvarez & Marsal Taxand's west coast practice, led by Melody Summers, has been involved in numerous transactions and large tax projects during the past year. It has advised several US companies on the reorganisation of their China operations; it has ... [more]

Alvarez & Marsal Taxand's west coast practice, led by Melody Summers, has been involved in numerous transactions and large tax projects during the past year. It has advised several US companies on the reorganisation of their China operations; it has carried out the global risk evaluation of a company with numerous manufacturing and sales locations and advised it on restructuring along globally efficient lines; and it has represented clients in IRS and state controversy matters. The practice recently acquired two new managing directors: Kent Wisner, who joined the firm from K&L Gates in November 2011, and Blake Davis, formerly international tax director at Deloitte, who joined Alvarez & Marsal Taxand in March 2012.

[hide]

Deloitte's Washington DC practice has seen an uptick in client demand for due diligence work and evaluation of strategic acquisitions. Tim Tuerff, the Washington National tax leader, said companies want to be more efficient, not just in terms of tax, ... [more]

Deloitte's Washington DC practice has seen an uptick in client demand for due diligence work and evaluation of strategic acquisitions. Tim Tuerff, the Washington National tax leader, said companies want to be more efficient, not just in terms of tax, but in general. The practice comprises a staff of 41 in international tax and 29 in transfer pricing. Arin Mitra heads the Washington national transfer pricing group.

[hide]

Ernst & Young's Washington DC practice comprises two offices: the national tax office, which is legislation focused and headed by Jonny Lindroos, and a practice office based in McLean, Virginia, a suburb of the Washington DC metropolitan area. Professionals ... [more]

Ernst & Young's Washington DC practice comprises two offices: the national tax office, which is legislation focused and headed by Jonny Lindroos, and a practice office based in McLean, Virginia, a suburb of the Washington DC metropolitan area. Professionals in the national tax practice report that clients are looking to align their global tax position with overall business strategy to maintain a competitive advantage and provide value to shareholders. The group, in collaboration with Ernst &Young's network, helps clients manage global tax risks, meet cross-border reporting obligations, and deal with transfer pricing issues. The national tax practice works on a full range of international tax services, from forward planning through reporting, to maintaining effective relationships with tax authorities. The demand for tax advice in Washington, DC has been growing as many companies from the aerospace and defence industries, and the high-tech, hospitality, and consultancy sectors, for example, are moving to the US capital to be close to central government. Ernst & Young has added staff to its Washington DC practice to meet the demand. Four new partners have joined in the last year: Matthew Stevens from Alston & Bird; Al Paul from Dell; Natan Leyva from Bingham McCutchen; and Jeff Chamberlain, who relocated from Ernst & Young in Denver. The practice also added three new executive directors. Dick McAlonan left the firm early in 2012 to join the IRS as director of its Advance Pricing and Mutual Agreement programme.

[hide]

The District of Columbia tax group of Skadden, Arps, Slate, Meagher & Flom, includes 13 partners and 33 fee earners, who offer services in M&A, spin-offs, transfer pricing, dispositions, partnerships, joint ventures, bankruptcy restructurings, and financings. ... [more]

The District of Columbia tax group of Skadden, Arps, Slate, Meagher & Flom, includes 13 partners and 33 fee earners, who offer services in M&A, spin-offs, transfer pricing, dispositions, partnerships, joint ventures, bankruptcy restructurings, and financings. Led by Fred Goldberg, co-head of Skadden's tax group nationally, the Washington DC practice has played a leading role in global settlements, fast-track appeals settlements, pre-filing agreements, and similar expedited resolution strategies. In the past year, Skadden advised independent power generator and developer of power plants AES Corporation on its $3.5 billion acquisition of DPL, a regional electric and utility company. The firm also represented Northeast Utilities in its merger-of-equals with NSTAR to create one of the nation's largest electric utilities with an enterprise value of $17.5 billion. The combined company will retain the name Northeast Utilities.

[hide]

Baker & McKenzie's Washington DC practice comprises 11 partners and 15 fee earners, offering services in international tax, transfer pricing and tax litigation. The practice, led by North American tax practice group chairman Leonard Terr and Duane Webber, ... [more]

Baker & McKenzie's Washington DC practice comprises 11 partners and 15 fee earners, offering services in international tax, transfer pricing and tax litigation. The practice, led by North American tax practice group chairman Leonard Terr and Duane Webber, also employs five economists, three analysts and one litigation support specialist. The practice serves as Boeing's main outside tax counsel, advising the aerospace and defence company on worldwide tax matters, including integrating aspects of acquisitions such as Jeppesen, Aviall, Carmen Systems, and others. It also assists with tax controversy matters, as well as tax compliance and planning. Projects concluded this year include successful resolution with the IRS Appeals Office of all issues for a five-year cycle and all issues for another two-year cycle. Clients for which Baker & McKenzie did significant new work in 2011 include American Air Liquide, Computer Sciences, General Dynamics, The Hershey Company, and Metropolitan Life Insurance. The firm also acquired three new partners: Mary Bennett rejoined in October 2011 from the OECD where she was head of the tax treaty, transfer pricing, and financial transactions division; Joshua Odintz joined during the same month from the US Treasury where he served as senior adviser for tax reform to the assistant secretary for tax policy; and the most recent addition is Anne Batter, who joined Baker & McKenzie from Miller & Chevalier. North American tax practice group co-chairman Thomas May transferred to the firm's New York office in January 2012.

[hide]

Bingham McCutchen's Washington DC office employs 22 partners and 17 fee earners who provide clients with services in corporate tax, transfer pricing, and tax disputes. Apart from their DC-based clients, Bingham's Washington DC practice also represents ... [more]

Bingham McCutchen's Washington DC office employs 22 partners and 17 fee earners who provide clients with services in corporate tax, transfer pricing, and tax disputes. Apart from their DC-based clients, Bingham's Washington DC practice also represents a large number of Wall Street financial institutions. In a deal announced on April 30 2012, the Bingham team served as tax counsel to Energy Transfer Partners in its acquisition of energy transportation and distribution company Sunoco for about $5.3 billion. The combination will create one of the largest energy partnerships in the country. Bingham previously acted as tax counsel for Energy Transfer Equity in its purchase of Southern Union. Lead advisers on the transaction were Bill McKee, Brad Whitehurst, Jasper Howard, Mike Schultz, and Gary Huffman. John Magee, Hardy Blanchard and James Bridgeman are the lead practitioners for Dow Chemical in a $320 million tax dispute: Chemtech Royalty Associates, L.P v United States. The case involves Dow's use of a partnership structure to monetise patent and chemical plant assets and raise minority equity financing from investors. A bench trial took place in the US District Court for the Middle District of Louisiana in June 2012. Post trial briefs have been filed.

[hide]

Mayer Brown's eight partners and seven fee earners staffing in Washington DC cover corporate tax, transfer pricing and tax disputes. Kenneth Klein and Rafic Barrage, are representing two major shipping companies before the IRS in connection with novel ... [more]

Mayer Brown's eight partners and seven fee earners staffing in Washington DC cover corporate tax, transfer pricing and tax disputes. Kenneth Klein and Rafic Barrage, are representing two major shipping companies before the IRS in connection with novel shipping tax and transfer pricing issues. The practice is also advising a wind farm owner/operator in connection with the financial restructuring of a wind farm. Because the wind farm is underperforming, the tax equity investors have maximised the losses they can recognise for tax purposes without increasing their at-risk investment. Mayer Brown tax professionals, led by Jeffrey Davis, are advising the operator on restructuring the tax equity and bringing in an additional equity investor to ensure that the value of the tax benefits (including production tax credits and depreciation) are not lost. If a new investor is not brought in, the Mayer Brown team will also advise in connection with a workout of the debt. The original financing depended on the ability to monetise the tax benefits efficiently, so ensuring that happens is critical to saving the project and avoiding a foreclosure.

[hide]

McDermott Will & Emery's Washington DC tax practice, led by Stephen Wells, advise major Fortune companies, financial institutions and other large organisations requiring complex and innovative tax structuring. Client work focuses on the tax aspects of ... [more]

McDermott Will & Emery's Washington DC tax practice, led by Stephen Wells, advise major Fortune companies, financial institutions and other large organisations requiring complex and innovative tax structuring. Client work focuses on the tax aspects of large M&A deals, corporate restructurings and high-profile advisory work. Around 50% of the practice is transactional and the other half is advisory. McDermott's DC team is the principal outside tax counsel to Tribune, representing the multimedia company on the formation of a partnership joint venture with Scripps Networks Interactive to own The Food Network and The Cooking Channel. The partnership has assets of more than $5 billion and is the world's largest producer and distributor of television programming related to food and cooking. Other work for Tribune during the past year included advice on various IRS audit matters and tax planning in connection with the company's emergence from bankruptcy. McDermott's national tax controversy practice is also based in Washington DC. Led by Jean Pawlow, the 40-member practice represents the world's largest corporations on US and international tax issues. There has been a significant increase in the number of cases being heard in the Tax Court over the past year and the firm has achieved a number of victories for taxpayers. The practice is also assisting clients in complying with the IRS's new guidelines regarding uncertain tax positions, which has led to a large amount of confusion and uncertainty among corporate taxpayers.

[hide]

Clients say they choose to work with Miller & Chevalier because of the successful outcomes and timely and practical advice it delivers. "[They offer] a combination of great technical expertise, advice regarding risk, and practical solutions," said one ... [more]

Clients say they choose to work with Miller & Chevalier because of the successful outcomes and timely and practical advice it delivers. "[They offer] a combination of great technical expertise, advice regarding risk, and practical solutions," said one client. George Hani, vice Chairman of the tax department, is also well-respected and trusted by taxpayers. The firm's Washington DC tax practice has great breadth and depth of technical expertise and experience, spanning business transactions and reorganisations, international tax, tax accounting, financial products, transfer pricing, criminal tax, excise tax and withholding issues. It also has in-depth know-how and expertise in a wide range of industries, including energy, auto manufacturing, telecommunications and utilities, financial services and insurance.

The practice, led by Patricia Sweeney, chairperson of Miller & Chevalier's tax department, secured the addition of a new, high-profile member. Kevin Downing joined the firm's criminal tax practice in June 2012 after leaving the Department of Justice where he served as federal prosecutor and most recently as senior litigation counsel. In February 2012, the firm also hired James Warren and Alexander Zakupowsky as members. Both were partners of the tax, energy and utilities practices at Winston & Strawn. Miller & Chevalier lost Robert Kirschenbaum, a transfer pricing specialist, to Bingham McCutchen in August 2011 and Dwight Mersereau to McDermott Will & Emery in January 2012.

[hide]

Led by Jerome Libin, Sutherland Asbill & Brennan's Washington DC practice comprises 25 partners and 34 fee earners. In May 2012, the firm expanded its insurance tax practice, an area of particular strength, hiring Dennis Allen and Kristan Rizzolo, who ... [more]

Led by Jerome Libin, Sutherland Asbill & Brennan's Washington DC practice comprises 25 partners and 34 fee earners. In May 2012, the firm expanded its insurance tax practice, an area of particular strength, hiring Dennis Allen and Kristan Rizzolo, who were partners at now defunct Dewey & LeBoeuf. The practice is also particularly active in the consumer goods, technology, telecommunications, broadcasting, and manufacturing industries. Vanessa Scott was promoted to partner in January 2012. She is the practice's specialist in the healthcare field.

[hide]

The three partners and four other tax lawyers in Freshfields Bruckhaus Deringer's New York and Washington DC offices work together as one team, led by Gregory May. The firm advises US and international clients on M&A, capital markets, investment funds, ... [more]

The three partners and four other tax lawyers in Freshfields Bruckhaus Deringer's New York and Washington DC offices work together as one team, led by Gregory May. The firm advises US and international clients on M&A, capital markets, investment funds, derivatives and structured products, finance and corporate tax planning. In September 2011, the team advised the consortium – comprising Goldman Sachs Infrastructure Partners and Abertis Infraestructuras – in connection with the successful bid for the proposed long-term concession of the PR-22 and PR-5 toll roads in Puerto Rico. The $1.08 billion project is the first toll road concession to be procured through a public-private partnership (PPP) as part of the Puerto Rican government's PPP initiative.

[hide]

Sullivan & Cromwell's Washington DC tax practice specialises in corporate finance, financial institutions, and international investment and trade. The DC lawyers routinely work with the firm's other offices in the US and abroad. The national tax controversy ... [more]

Sullivan & Cromwell's Washington DC tax practice specialises in corporate finance, financial institutions, and international investment and trade. The DC lawyers routinely work with the firm's other offices in the US and abroad. The national tax controversy practice, led by former IRS chief counsel Donald Korb, is based in Washington DC. The practice is serving as counsel to a European company in an IRS examination involving a debt/equity issue with close to $4 billion in potential tax liabilities at stake. The IRS has raised such issues in a significant number of recent examinations where the non-US parent, or an entity in the non-US group, has made loans to its US subsidiaries. The firm believes that this case, which is a variation of those facts, represents the largest potential adjustment that the tax authority has proposed to date.

[hide]

White & Case's 10 tax lawyers in its Washington DC practice provide clients with services in transactional tax, tax planning, legislative and advisory services, and tax litigation. Linda Carlisle heads the transactional tax practice, while Michael Quigley ... [more]

White & Case's 10 tax lawyers in its Washington DC practice provide clients with services in transactional tax, tax planning, legislative and advisory services, and tax litigation. Linda Carlisle heads the transactional tax practice, while Michael Quigley is tax controversy leader. Clients describe their experience with the firm as "excellent". "Linda is responsive and capable and one of the best at working with the IRS and Treasury," said one client. On May 4 2012, White & Case's team won a court case related to a denial of tax deductions for their client, Great American Life Insurance. In 1995, the insurer increased its tax reserves by $59 million, which it deducted for US federal income tax purposes. The IRS denied the deduction and a lengthy dispute began, with the taxpayer suing the government. A federal district court in Ohio entered an order permitting the life insurer's entire $59 million deduction. The US Court of Appeals for the 6th Circuit upheld the order. The case is the only reported decision on the issue presented. Tax litigator Kim Marie Boylan joined the DC practice in July 2011 from Latham & Watkins, where she was a partner.

[hide]

Led by Henry Birnkrant, Alston & Bird's tax practice in Washington DC, comprises 10 partners and 11 fee earners with a breadth of expertise in federal, state and local tax, cross-border structuring, and transfer pricing. In the last year, the practice ... [more]

Led by Henry Birnkrant, Alston & Bird's tax practice in Washington DC, comprises 10 partners and 11 fee earners with a breadth of expertise in federal, state and local tax, cross-border structuring, and transfer pricing. In the last year, the practice has advised a US entity on a unilateral advance pricing agreement that covers all of the taxpayer's export transactions to its European affiliates and the licensing of technology to an Irish manufacturing subsidiary. The methodology developed aggregates across all European entities to avoid the need to test transactions to each entity separately. The methodology includes a negotiated formula that avoided the complexity and burden associated with using a profit split model to determine the return to the European-owned intangibles and has substantially reduced the client's compliance costs. The estimated transaction volume during the APA-covered period is $2.4 billion.

[hide]

Alvarez & Marsal – Taxand's Washington DC practice, headed by federal and state and local tax (SALT) leader Tom Aiello, advises clients on a wide range of tax-related issues. In the last year, the practice has advised clients in competent authority proceedings, ... [more]

Alvarez & Marsal – Taxand's Washington DC practice, headed by federal and state and local tax (SALT) leader Tom Aiello, advises clients on a wide range of tax-related issues. In the last year, the practice has advised clients in competent authority proceedings, restructuring US operations of foreign multinationals and providing sales tax refund analysis for overpayments. Alvarez & Marsal also carries out transfer pricing planning studies and R&D credit studies. It advises taxpayers on supply chain restructuring, intellectual property transactions and international acquisitions; and provides assistance with IRS examinations and litigation support. The practice is also active in the financial services sector, advising financial institutions on international financial products and operations.

[hide]