Tax
Tax overview
In our dynamic international economic environment, tax regimes evolve. Increased globalization creates complex tax issues requiring deep knowledge of national tax laws, tax treaties, information-sharing programs and a keen understanding of the cross-border tax implications of most transactions. Our clients rely on our extensive experience, technical knowledge and global tax presence for sophisticated and practical advice that helps them reach their business goals. Our lawyers work closely with our other leading transactional practice groups to provide integrated tax advice necessary to successfully complete transactions.
Our offering
Our full-service Tax Practice works collaboratively with the Firm's transactional, financing and disputes practices, covering comprehensive legal needs across:
M&A, spin-offs and joint ventures
- We advise on the most tax-efficient transactional structures within a single jurisdiction or across multiple jurisdictions.
- We support private equity clients on a broad range of tax issues, including the tax aspects of the acquisition and disposition of portfolio companies, and coordinating US and non-US tax aspects of cross-border transactions, as well as incentive compensation arrangements.
- We advise on the tax-efficient structuring of spin-offs, carve-outs and joint ventures.
Tax structuring, restructuring and insolvencies
- We advise corporates, financial institutions and financial sponsors on tax-efficient ways to structure both cross-border and domestic holdings and investments.
- We regularly help clients to restructure investments in response to changing commercial and regulatory needs.
- We offer tax advice on insolvencies and distressed restructurings, including the federal income tax aspects of bankruptcy.
Funds
- We help private fund sponsors, fiduciaries and institutional investors across developed and emerging markets meet their particular tax and investment objectives.
- We work alongside the Firm's investment funds global industry group to integrate tax advice with broader structural and transactional support.
Equity offerings and debt financing
- We advise our corporate and financial institution clients through offerings in multiple jurisdictions.
Renewable energy and tax equity
- We advise on the development, construction and financing of renewable energy projects.
- We support the qualification for tax credits, and their monetization, using various tax equity structures (such as partnership flips, leases and sale-leasebacks), transferability and direct pay.
Tax controversy
- Whether a dispute is anticipated, 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 help clients assess their global tax risk and work with them to develop strategies to mitigate that risk.
Complex and consequential matters
Brookfield Renewable
We advised Brookfield Renewable on its US$7 billion acquisition of Aypa Power, a Blackstone portfolio company that develops, owns and operates utility-scale energy storage and hybrid renewable energy projects.
Deutsche Bank AG, Singapore Branch
We advised Deutsche Bank AG, Singapore Branch and 17 other banks, as initial purchasers, on the Rule 144A/Regulation S offering of US$1 billion of 6.750% senior notes, due 2034, by Wynn Macau, Limited (Wynn Macau), a Hong Kong–listed leading developer, owner and operator of integrated destination casino gaming and entertainment resort facilities in Macau.
Ares Management funds
We advised Ares Management funds (Ares) on its preferred equity investment in Leaf Home alongside Gridiron Capital and co-investors.
Nomura
We advised Nomura on its entry into an agreement with Macquarie to acquire its US and European public asset management business for US$1.8 billion.
Grupo Aeroméxico, S.A.B. de C.V.
We advised Grupo Aeroméxico, S.A.B. de C.V. (Aeroméxico) on its US$275 million initial public offering.
Cobepa
We advised Cobepa on its entry into a partnership with Prosol, alongside funds managed by Apollo, Prosol’s founder and the management team, for the acquisition of Prosol from Ardian.
Interogo Infrastructure
We advised Interogo Infrastructure on its agreement to acquire a minority stake in Nordic Ferry Infrastructure (NFI), a leading Nordic maritime infrastructure platform, alongside Gotlandsbolaget and Laegernes Pension, from EQT Infrastructure V.
Perdaman Chemicals and Fertilisers Pty Ltd
We advised Perdaman Chemicals and Fertilisers Pty Ltd (Perdaman) on the development and financing of the US$4.2 billion greenfield Karratha Urea Project in Western Australia.