Tax

Shearman & Sterling's Tax Group, with tax lawyers in the United States and Europe, including France, Germany and the United Kingdom, plays an integral role in the firm's cross-border practice and provides local tax capability in various jurisdictions.  More particularly, for clients throughout the world, our Tax Group provides international strategic tax planning advice and representation on a variety of complex transactions (both local and cross-border), such as:

• Mergers and acquisitions, post-acquisition restructurings and reorganizations
  
  
• Spin-offs/split-offs and spin-merge transactions
  
  
• Equity offerings and debt financings
  
  
• Bankruptcy work-outs and insolvency restructurings
  
  
• Private equity transactions, including leveraged and management buy-outs
  
  
• Partnerships and other joint venture arrangements
  
  
• Debt-equity swaps, recapitalizations and distressed loan transactions
  
  
• Structured finance and tax-advantaged investments
  
  
• Derivatives and other financial instruments
  
  
• Investment and hedge funds and REITs
  
  
• Public and private real estate transactions

One emphasis of the Tax Group is representing multinational companies in cross-border transactions and financial offerings in multiple jurisdictions.  In order to meet the demands of our multinational clients, tax lawyers provide state-of-the-art advice in relation to tax law and its development on a global basis.  We also have considerable experience advising multinational companies in the reduction of overall tax costs inherent in operating in multiple jurisdictions and in developing tax-efficient investment and operating structures, as well as in developing tax-sensitive management/employee compensation packages and in expatriate taxation.

Our tax lawyers work with various investment banking firms and other financial advisors or institutions located worldwide in developing tax-efficient structures for financings, hybrid securities, acquisitions, dispositions, joint ventures and other investments.  Our substantial representation of major investment banks and financial institutions in the area of financial product development is an active source of business for the Tax Group.

Many new and long-time clients seek our counsel and representation in controversies and other matters involving tax authorities in the United States and Europe.  Tax lawyers throughout the firm represent clients in tax audits and litigation, in obtaining rulings from tax authorities, and in competent authority proceedings, as well as working with clients to obtain advance pricing agreements.  Shearman & Sterling has one of the premier tax litigation teams in the United States, advising clients on disputes with the Internal Revenue Service, both before the agency and in court.  We have tried cases in the United States Tax Court, the Court of Federal Claims, and the district courts, and briefed and argued appeals in several United States Circuit Courts.