Asset Management, Private Equity and Investment Funds: Our tax lawyers work closely with our Funds, Private Equity and Sovereign Wealth Funds practices to design and implement the appropriate tax structures for domestic and global private equity, venture capital, sovereign wealth, real estate investment trusts, renewable energy and numerous other investment funds and their portfolio companies. We represent taxable and tax-exempt investors, as well as sponsors and managers seeking to participate in such funds on a tax-advantaged basis. By structuring offshore centers to achieve tax efficiencies and advising on the reorganization and restructuring of existing financial arrangements arising out of leveraged transactions, we help clients achieve optimal tax objectives to maximize fund value.

Bankruptcy and Restructurings: We assist with the design and implementation of plans for the restructuring of debt and equity capital on behalf of domestic and multinational companies and their affiliates facing financial difficulties, including the use of favorable tax structures for reorganization, restructuring and workout plans, whether major or minor in nature. White & Case tax lawyers work closely with our Financial Restructuring and Insolvency practice to analyze immediate and long-term tax consequences in the representation of debtors, creditors, equity and creditor committees, financial advisors and trustees in and out of bankruptcy to develop innovative tax solutions to our clients' financial challenges.

Individual Tax and Estate Planning: Our tax lawyers work closely with our Global Private Clients practice to manage, preserve and transfer wealth. Advising on a broad range of issues, our lawyers work closely with advisors, accountants and investment professionals to achieve advantageous structures and estate plans that allow for tax-efficient transfers of assets. Our clients include individuals, multinational publicly-held corporations and their executives, charitable organizations and multi-generational families who control substantial personal and business assets in almost every region of the world, and may be materially affected by the varying tax regimes of the countries where they may have interests.

Mergers, Acquisitions, Divestitures and Spin-offs: In both cross-border and single-country deals, our tax lawyers are extensively involved in negotiating a diverse range of taxable and tax-free business transfers and restructurings. As a global firm, we offer domestic and international tax advice, putting our analytical abilities to work to structure tax-free reorganizations—including acquiring, combining, or spinning off entities or businesses—that help our clients close transactions with a minimum of tax liability. We represent acquiring and target entities, their shareholders, underwriters, investors, lenders, investors and their investment vehicles in conjunction with our Mergers & Acquisitions practice. Our objective is to achieve both tax-related efficiencies during the transaction and effective post-transaction structures, and we routinely provide enabling tax opinions on special structural solutions.

Partnerships and Joint Ventures: Many of our clients seek to structure their investment and business activities by way of flow-through vehicles that include partnerships, joint ventures or limited liability companies. Based on a thorough understanding of each business entity with which we work, our tax lawyers work with our Corporate practice on both domestic and international business structures such as joint ventures between large corporate entities, and start-up ventures among individuals. We have structured numerous complex financial arrangements for clients including cross-border repo transactions, international corporate restructurings, and foreign debt restructurings in multiple jurisdictions.

Project, Facility, Equipment Financings: Clients seeking to finance single-country and cross-border projects, facilities, or equipment look to White & Case for guidance to ensure maximum financial benefit and optimal tax treatment. We have structured transactions covering various assets including aircraft, rail, power plants, power generation, solar and wind turbine facilities and manufacturing facilities, among others. Working closely with our Energy, Infrastructure, and Project Finance and Asset Finance practices, we advise clients which include equity investors, lenders, manufacturers, corporate trustees, lessors, lessees and brokers. We create partnerships to preserve the economic benefits associated with each participant's interest, and may employ hybrid entities and instruments to minimize tax costs in a multijurisdictional transaction.

Real Estate Transactions: White & Case has substantial experience advising clients, including buyers, sellers and investors worldwide, on the planning and structure of tax-deferral and tax-advantaged real estate transactions, including acquisitions and sales, securitization transactions, lending arrangements, like-kind exchanges, off-shore entities, and loan restructurings. We work closely with our Real Estate practice to counsel clients on present and long-term risk regarding the use of special purpose vehicles (SPVs) and various real estate investment trusts (REITs). We also prepare arrangements for debt and equity convertible or participating obligations, restructurings and partnership agreements.

Securities and Financial Products: With deep experience in the nuances of securities and banking industries around the world, our lawyers advise on the tax aspects of structured financial products and complex derivatives transactions. Working with our Capital Markets and Corporate practices, we also help issuers, underwriters, borrowers, placement agents, investors, dealers and corporate trustees utilize the most tax-efficient mechanism for each public or private offering. Our tax practitioners have successfully led offerings of structured notes, debt, equity, and hybrid securities transactions and re-packagings worldwide. In addition, we advise on the tax-efficient use of special purpose vehicles (SPVs) and assist with the innovative design and implementation of monetizing and leveraging securities positions through capital markets.

Tax Advisory Services: Our tax lawyers serve as primary tax advisors and outside general tax counsel to public and private businesses, from start-ups to multinationals, on all tax aspects of their operations in multiple jurisdictions. Advising on tax-efficient investments, expatriate taxation, tax-sensitive employee and management compensation and benefits matters, customs duties, legislative and policy developments, double-taxation arrangements and reporting requirements, many high-profile and rapidly expanding businesses seek our broad expertise and technical capabilities.

Tax Controversy and Litigation: As regulatory burdens become more complex, the potential for tax controversy increases. While our efforts are aimed at avoiding such conflicts through competent advice, detailed contracts and skillful negotiation, at times the desired outcome can only be obtained in adversarial administrative proceedings or in court. Our tax lawyers offer a range of litigation and alternative dispute resolution options before government and tax authorities to address examinations, investigations, audits, appeals and diverse tax challenges. As we identify specific transactions that may increase a client's exposure to additional risks, penalties and investigations in the future, we are recognized for providing effective advice on preventative measures and successful representation of clients in wide-ranging domestic and cross-border tax controversies.

Transfer Pricing: As a premier provider of transfer pricing advice for transactions between affiliated companies, White & Case helps clients avoid the burdens of double taxation. This work often falls under the auspices of income tax treaties, which requires as much diplomacy as it does knowledge of tax matters. By leveraging our global network, our lawyers are able to work with both sides in a delicate negotiation simultaneously to bring the parties to common ground swiftly. This concerted effort positions us for success at the earliest possible point, whether the negotiations are unilateral with a single tax authority or conducted bilaterally through competent authority proceedings. We also offer a broad array of services in connection with advance pricing agreements, transfer pricing disputes, tax planning, as well as global tax minimization and cash repatriation strategies.