In the ever-changing economic environment, tax regimes similarly evolve. Today, governmental efforts to increase or maintain tax revenue levels pose new and difficult challenges for tax planning and dispute resolution for corporations, partnerships, and individuals alike.
Globalization also creates complex tax issues requiring deep knowledge of national tax laws, tax treaties, and information sharing programs. Given our global tax presence and over 90 tax professionals, clients routinely seek our advice on reaching their business goals in light of the multiplicity of national tax laws and the cross-border nature of today's complex tax issues.
Tax efficiency, risk reduction, avoidance of tax controversy, and the successful resolution of an unavoidable dispute are goals that can best be met where the tax team possesses strong national and cross-border experience. We effectively and efficiently partner with our clients to meet these goals.
Whether the tax issues involve a single country or are cross-border, encompass planning for tax efficiency or require resolution of a civil or criminal tax controversy or investigation, our global Tax Group partners with our clients to develop effective solutions.
We understand the business and legal intricacies of international business and taxation. Our group is recognized globally for its forward-thinking approach on tax matters as well as precedent-setting firsts in tax planning for transactional matters including M&A, private equity, capital market, project finance, family office, and real estate as well as for executive compensation, transfer pricing, tax dispute resolution, competent authority, and investigative matters.
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AWARDS & RECOGNITION
Tier 1 Ranking for Tax (New York) and Trusts and Estates Law (National and New York)
U.S. News & World Report—Best Lawyers: Best Law Firms 2018
Tax Disputes Law Firm of the Year
Global Law Experts 2016
European M&A Tax Deal of the Year and European Private Equity Tax Deal of the Year
International Tax Review Awards 2017
"Valued for both its tax planning and tax controversy expertise. The team is a popular choice for high-value M&A support and offers clients enviable geographic coverage with key strengths in the USA, the UK, France and Russia… ‘Very responsive, very good service, a very high-quality firm.'"
Chambers Global 2017
"Clients indicate that the firm has the necessary resources to handle complex pan-European mandates: 'In major cases we work on international matters where we need multi-jurisdictional help.'"
Chambers Europe 2017
Recognized for International Tax, Contentious US Tax and Non-Contentious US Tax
The Legal 500 US 2017
Transfer Pricing Law Firm of the Year in Washington, DC
Global Law Experts 2017
Tax planning and transactional
Tax advice on US$20 billion joint venture with Dow Chemical on Saudi chemicals complex
Lawyers from multiple jurisdictions and practices, including Tax, provided Saudi Aramco with advice on its joint venture with the Dow Chemical Company to build and operate a US$20 billion world-scale integrated chemicals complex in Saudi Arabia.
Tax advice helps facilitate US$13.5 billion healthcare acquisition
In a major acquisition, the acquiring company needed astute tax advice to facilitate the deal. Our tax team provided principal tax advice to Zimmer Holdings Inc., a world leader in musculoskeletal health solutions, in its US$13.5 billion acquisition of Biomet, Inc., one of the world's leading medical device manufacturers.
Cross-border tax issues resolved in Chinese acquisition of US company
We leveraged our knowledge of US and China tax laws as well as our cross-practice strength in advising Shenzhen Pharmaceutical Co., Ltd., a public Chinese company, and its US subsidiary, Hepalink USA Inc., in its acquisition of Scientific Protein, LLC, a leading global manufacturer and supplier of active pharmaceutical ingredients. This transaction is one of the few acquisitions by a public Chinese company of a US privately-held target.
Multijurisdictional tax structuring advice provided on sale by world-leading software company
When Avast Software, a leading antivirus company, and a selling shareholder consortium needed advice on the sale of a significant minority stake to CVC Capital Partners, a private equity firm, they turned to White & Case. The team knew Avast and its needs, and also understood the demands of private equity sponsors. Close cooperation throughout by the tax and transaction teams helped make this a success.
Given the breadth of our international footprint, successfully resolving tax disputes for multinational clients is the focus of our tax controversy practice. Whether a dispute is anticipated, is already at the audit or administrative settlement stage, or has progressed to encompass alternative dispute resolution techniques or litigation, we work closely with our clients to develop the most effective and creative solutions. We also help clients assess their global tax risk and work with them to develop strategies for mitigating that risk.
Our tax lawyers work closely with, and as a part of, our investment funds global industry group in helping private investment fund sponsors, fiduciaries and institutional investors in existing and emerging markets achieve their particular tax and investment objectives. Our clients include established and emerging private fund sponsors around the world, as well as alternative asset groups, international financial institutions, sovereign wealth funds and other institutional investors.
Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be addressed. Our team of tax controversy and transfer pricing lawyers possess these attributes and appear regularly before all levels of domestic and foreign tax authorities and competent authorities. Our international breadth affords us the best opportunity to take a bilateral or multilateral approach to resolving disputes, including through the use of Advance Pricing Agreements, and we frequently work with the competent authorities in domestic jurisdictions and abroad to obtain the best results for our clients.
Once a global acquisition is completed, the company must then integrate the acquired business with its legacy business. Unsuccessful integration is the leading cause of failed acquisitions. We advise on all aspects of global post-acquisition integration projects: from international tax planning – to designing the combined company's go-forward corporate, labor, intellectual property, real estate, supply chain and commercial structure – to executing all integration transactions on a global basis. Our team of tax lawyers works closely with our lawyers in other disciplines to provide clients a single solution for implementing global integration projects effectively and efficiently. We also devise solutions for all types of internal restructurings, including establishing holding company structures, and restructuring a corporate group in anticipation of a spin-off or sale of a global division or business line.
We regularly represent a wide variety of private equity firms on a broad range of tax issues. In particular, we advise on the tax aspects of the acquisition and disposition of portfolio companies, coordinating US and non-US tax aspects of cross-border transactions. We also represent the portfolio companies with respect to add-on acquisitions and ongoing tax advice.
We advise high-net-worth individuals and families in all aspects of estate planning, estate and trust administration, multigenerational wealth transfer planning, income taxation, estate and gift taxation, the formation and administration of tax-exempt charitable entities, and prenuptial and post-nuptial planning. Given our global reach, we typically work with non-US individuals to minimize the tax consequences of moving to the US and investing in the US. In addition, we often advise US individuals on the increasing complex US tax and reporting requirements imposed on those who own accounts and assets abroad. Another aspect of our practice focuses on complex estate-related litigation, including in the multijurisdictional context.