Consistent with its strong international orientation, the Firm has developed particular expertise in tax planning for cross-border acquisitions and financial transactions, corporate restructurings, joint ventures, the use of hybrid entities, licensing and distribution arrangements, equipment leasing, project finance and foreign investment in the United States. The tax group also represents clients in audits and controversies before the Internal Revenue Service and state and local tax authorities. Other departments of the Firm often work closely with the tax group to devise solutions for complex tax problems.

The Firm's experience in tax matters includes the following:

• Representation of high net worth individuals in connection with the structuring of assets for tax and estate planning purposes.
• Designing and implementing a management-led buyout and internal restructuring of a foreign-based corporation and its U.S. operations.
• Representation of a member of Private Foundations before the Internal Revenue Service.
• Advising on the application of various tax treaties to a broad range of investment and business operations in the United States, Latin America and Europe.
• Advising internet start-up companies on both U.S. and foreign tax issues of the company, its shareholders and its employees.
• Advising funds investing in internet start-up companies.
• Advising internet company "incubators" on U.S. and foreign tax issues.
• International tax planning in connection with a joint venture between a U.S. company and foreign investors for the satellite broadcasting of television programs in the Middle East.
• Representation of a transnational joint venture in development of the optimal tax structure for acquiring, holding and disposing of significant ownership interests in high-tech companies.
• Acting as special international tax counsel for structuring a cross-border corporate reorganization and subsequent initial public offering.
• Representation of a foreign oil company in connection with cross-border sale-leaseback financing transactions involving offshore oil platforms.
• Advising with respect to transfer pricing cases involving potential Internal Revenue Service adjustments to pricing on the sale or transfer of tangible and intangible property, or the rendition of services, between related parties, including analysis of appropriate transfer pricing methodologies, developing measures to prevent the application of transfer pricing adjustments and penalties, and applying for and negotiating advance pricing agreements with the IRS.
• International tax planning in connection with tax-advantaged receivables financing transactions for foreign and U.S. corporations.
• Representation of a major Japanese bank in a controversy with the Internal Revenue Service involving income taxes in connection with currency and interest rate swaps.
• International tax planning in connection with a foreign corporation's joint venture investment in a major U.S. fuels refinery.
• International tax planning in connection with a U.S. corporation's joint venture investment in a foreign telecommunications project.
• Representation as special tax counsel to a foreign finance company in connection with the issuance of American Depositary Receipts traded on the New York Stock Exchange.
• Obtaining a private letter ruling from the Internal Revenue Service for a U.S. multinational corporation with respect to the tax-free spin-off of a subsidiary.
• Representation of a Fortune 200 corporation in extended litigation before the United States Tax Court involving multiple income tax issues.
• Tax planning for the development and operation of a privately-owned U.S. toll road.
• Structuring several limited liability entities for internationally disseminated on-line medical services.
• Representation of a welfare benefit plan and its participating employers in litigation before the United States Tax Court.
• Assisting a publicly supported tax-exempt organization before the Internal Revenue Service ruling division in connection with a large single donation.
• Advice regarding the international and domestic tax implications of aircraft transactions