Tax Corporate & Finance

  • AmeriGas Partners, L.P. | in its acquisition of the propane operations of Energy Transfer Partners L.P.
  • ArcelorMittal | in the sale of Skyline Steel LLC to Nucor Corporation.
  • Deere & Company | on the restructuring of its foreign operations.
  • Dow Chemical Company | on structuring a $20 billion joint venture with Saudi Aramco.
  • Groupe Danone | in its effort to acquire Pfizer’s infant nutrition business.
  • IntercontinentalExchange (ICE) | a leading operator of global over-the-counter (OTC) markets, clearing houses and regulated futures exchanges, on its launch of a new clearing facility for OTC Non-Deliverable Forward Foreign Exchange (FX) contracts.
  • Liberty Global | in its $23 billion acquisition of Virgin Media through a new U.K. holding company.
  • Marriott International, Inc. | on U.S. tax matters relating to splitting the company’s businesses into two separate, publicly traded companies.
  • Schneider Electric | in its acquisition and post-acquisition restructuring of Telvent GIT S.A.
  • SunGard Data Systems Inc. | in the bifurcated sale of its Higher Education businesses to affiliates of Hellman & Friedman for an aggregate cash purchase price of $1.775 billion.
  • Synthes, Inc. | a premier global manufacturer of orthopaedic devices, in its acquisition by Johnson & Johnson, the world’s most comprehensive and broadly based manufacturer of health care products, in a transaction valued at $21.3 billion.

Tax Controversy

  • Ford Motor Company | in a case involving whether bonuses paid to UAW members to secure ratification of a collective bargaining agreement are “wages” for FICA and FUTA withholding purposes. This is the lead case for the domestic auto makers and includes claims for UAW members as well as Ford.
  • Freddie Mac Tax Court Case | in a case involving a $2.5 billion dispute with the IRS involving the tax treatment of derivatives used to hedge financial risk.

Key Contact(s)

Connect With Us