Tax

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Gibson Dunn Advises Welltower in $1.035 Billion Private Offering of Exchangeable Senior Notes

Gibson, Dunn & Crutcher LLP advised Welltower Inc. and Welltower OP LLC in a private offering of $1.035 billion aggregate principal amount of Welltower OP's 3.125% Exchangeable Senior Notes due 2029.

Firm News | July 11, 2024

Gibson Dunn Advises Mondelēz International in CAD-Denominated Offering of C$650 Million of Notes

Gibson Dunn represented Mondelēz International, Inc. (NASDAQ: MDLZ), one of the world's largest snack companies, in its CAD-denominated, SEC-registered offering of C$650,000,000 aggregate principal amount of 4.625% Notes due 2031. 

Firm News | July 3, 2024

IRS and Treasury Issue Final Regulations on Prevailing Wage and Apprenticeship Requirements under the IRA

The IRS and Treasury published final Treasury regulations (the “Final Regulations”) on the prevailing wage and apprenticeship requirements (the “PWA Requirements”) that taxpayers must satisfy to receive the full amount of certain tax credits provided for in the Inflation Reduction Act of 2022 (the “IRA”).

Client Alert | July 2, 2024

Environmental Groups Challenge Louisiana’s Primacy Over Class VI Wells

The groups are seeking a total reversal of the EPA’s decision to grant Louisiana primacy over Class VI wells.

Client Alert | June 28, 2024

Supreme Court Overrules Chevron, Sharply Limiting Judicial Deference To Agencies’ Statutory Interpretation

The Supreme Court overruled Chevron v. Natural Resources Defense Council, a landmark decision that had required courts to defer to agencies’ reasonable interpretations of ambiguous statutory terms.

Client Alert | June 28, 2024

Gibson Dunn Advised the Underwriters on LandBridge Company LLC’s Initial Public Offering

Gibson, Dunn & Crutcher LLP is advising the underwriters on LandBridge Company LLC’s initial public offering.

Firm News | June 28, 2024

Gibson Dunn Advises SolarEdge Capped Call Transaction

Gibson Dunn advised SolarEdge Technologies, Inc. on a private offering of $300 million aggregate principal amount of the Company’s 2.250% convertible senior notes due 2029 and the concurrent capped call transactions.

Firm News | June 28, 2024

Gibson Dunn Advises Initial Purchasers on $750 Million Senior Notes Offering by Fairfax Financial Holdings Limited

Gibson Dunn represented the initial purchasers led by BofA Securities, Inc., BMO Capital Markets Corp., Citigroup Global Markets, Inc., and J.P. Morgan Securities LLC, as joint book-running managers in a private offering by Fairfax Financial Holdings Limited (the “Company”) of $750 million senior notes.

Firm News | June 24, 2024

Best Lawyers in France 2025 Recognizes 20 Gibson Dunn Attorneys

Best Lawyers and Best Lawyers: Ones to Watch in France 2025 recognized 20 Gibson Dunn attorneys, and 17 Gibson Dunn attorneys have been recognized as leading lawyers in their respective practice areas.

Firm News | June 20, 2024

Best Lawyers in the United Kingdom 2025 Recognizes 25 Gibson Dunn Attorneys

Best Lawyers and Best Lawyers: Ones to Watch in the United Kingdom 2025 recognized 25 Gibson Dunn attorneys, including 22 Gibson Dunn attorneys recognized as leading lawyers in their respective practice areas. 

Firm News | June 20, 2024

Supreme Court Holds That 2017 Mandatory Repatriation Tax Does Not Violate The Sixteenth Amendment

Today, in a case widely seen as a test of Congress’s ability to enact wealth taxes, the Supreme Court held narrowly that Congress did not violate the Sixteenth Amendment by requiring U.S. shareholders to pay a one-time tax on undistributed corporate earnings of controlled foreign corporations.

Client Alert | June 20, 2024

U.S. Department of Treasury Releases Joint Policy Statement and Principles on Voluntary Carbon Markets

The Policy Statement asserts that “the U.S. Government is playing an increasingly important role in carbon credit markets” and serves to “codify the U.S. Government’s approach to advance high-integrity voluntary carbon markets.”

Client Alert | June 17, 2024

IRS and Treasury Issue Guidance on Related-Party Basis Adjustments

This alert describes the IRS’s recent focus on partnerships, provides background on basis adjustments under subchapter K, and discusses the Related-Party Basis Adjustment Guidance issued earlier today.

Client Alert | June 17, 2024

Gibson Dunn Ranked in 2024 U.S. Legal 500

Gibson Dunn earned 62 practice area rankings, including 19 top-tier rankings in the 2024 edition of The Legal 500 – United States.

Firm News | June 12, 2024

IRS and Treasury Issue Proposed Regulations on Tech-Neutral Tax Credits for Clean Energy Projects

The Proposed Regulations generally would apply to projects placed in service after December 31, 2024, once final regulations are published in the Federal Register.  

Client Alert | June 12, 2024

Supreme Court Holds That A Corporation’s Life Insurance Proceeds Used To Redeem A Decedent’s Shares Must Be Included In Federal Estate Tax Calculation

Today, the Supreme Court unanimously held that the proceeds from a life insurance policy taken out by a corporation to redeem a decedent shareholder’s stock are a corporate asset for federal estate tax purposes.

Client Alert | June 6, 2024

Gibson Dunn Advises Related Argent on Joint Venture to Create Third Brent Cross Town Built-to-Rent Development

Gibson, Dunn & Crutcher LLP advised Related Argent on its joint venture with NTT UD Europe Limited, a subsidiary of leading Japanese telecommunications group Nippon Telegraph and Telephone, to take forward the third Build-to-Rent development at Brent Cross Town.

Press Releases | May 29, 2024

Chambers and Partners Transfer Pricing 2024

Six Gibson Dunn lawyers contributed to the Chambers and Partners Transfer Pricing 2024 guide.

Article | May 24, 2024

IRS and Treasury Issue Notice 2024-41 Providing Additional Guidance on “Domestic Content” for ITC- and PTC-Eligible Projects

The Notice provides a new elective safe harbor that should reduce the practical difficulties that taxpayers face in seeking to demonstrate that their clean energy projects are eligible for the Domestic Content Bonus Credit by reducing the circumstances when taxpayers will be forced to engage in cumbersome or impractical substantiation of third-party costs.

Client Alert | May 20, 2024

Important Updates on Spin-Offs and Debt Exchanges: Revenue Procedure 2024-24 and Notice 2024-38

Our lawyers review the U.S. Internal Revenue Service and Treasury Department’s updated guidelines on spin-offs and debt exchanges.

Client Alert | May 6, 2024

IRS and Treasury Issue Final Regulations Regarding Domestically Controlled REIT Qualification Test

The Final Regulations modify the “look-through” rule for certain domestic C corporations, and introduce a new ten-year transition rule.

Client Alert | April 26, 2024

Gibson Dunn Advises ESAB Corporation on $700 Million Senior Notes Offering

Gibson Dunn represented ESAB Corporation on a private placement offering of $700 million in aggregate principal amount of their 6.25% notes due 2029. 

Firm News | April 11, 2024

Gibson Dunn Advised Ardian in Partnership with Indigo Group to Form New Canadian Joint Venture to Invest in Parking Assets

Gibson Dunn advised Ardian, a world-leading private investment house, in its partnership with Indigo Group, a global player in parking and urban mobility, to form a new Canadian joint venture to invest in parking assets.

Firm News | April 8, 2024

Gibson Dunn Ranked in Legal 500 EMEA 2024

The Legal 500 EMEA 2024 has recommended Gibson Dunn in 29 categories in Belgium, France, Germany, Saudi Arabia and UAE.

Firm News | March 27, 2024

Gibson Dunn Ranked in Chambers Europe 2024

Gibson Dunn received 38 rankings in Chambers Europe 2024: 27 individual rankings and 11 firm rankings.

Firm News | March 14, 2024

Tax Partner Benjamin Rapp to Join Gibson Dunn in Germany

Gibson, Dunn & Crutcher LLP is pleased to announce that Benjamin Rapp will join the firm in Germany as a tax partner.

Press Releases | February 8, 2024

Gibson Dunn Advises UCK Partners on the Formation of UCK Partners III

Gibson Dunn advised UCK Partners, a Seoul-headquartered private equity firm, on the formation of its third Korea-focused fund, UCK Partners III, at KRW1.1 trillion in commitments.

Firm News | February 2, 2024

Gibson Dunn Advises Asia Partners on Final Close of Second Fund, Asia Partners II LP

Gibson Dunn represented Asia Partners, a Singapore-based growth equity investment firm, on the final close of its second fund, Asia Partners II LP, at US$474 million in commitments.   

Firm News | January 11, 2024

The State of Louisiana Is Granted Primacy Over Class VI Wells

The U.S. Environmental Protection Agency (EPA) has given Louisiana primary enforcement authority over the state’s Class VI underground injection wells, which are used by the carbon capture and sequestration (CCS) industry to permanently sequester captured carbon in underground geological formations.

Client Alert | January 8, 2024

IRS and Treasury Unveil Registration Tool for Transferring and Receiving Direct Payments for IRA and CHIPS Act Tax Credits

On December 22, 2023, the IRS and Treasury unveiled their new pre-filing registration portal for transferrable and refundable tax credits under the Inflation Reduction Act of 2022 and the CHIPS and Science Act of 2022.

Client Alert | December 27, 2023

Tax Court Determines That Limited Partners Are Not Necessarily Exempt from Self-Employment Tax – The Limits of the Limited Partner Exception, as Such

The U.S. Tax Court has determined that limited partners are not necessarily exempt from self-employment tax.

Client Alert | December 19, 2023

Gibson Dunn Represents JPMorgan in $300 Million Term Loan to Perrigo

Gibson Dunn represented JPMorgan as dealer manager in connection with Perrigo’s tender offer for up to $300 million of its outstanding 3.9% senior notes due 2024.

Firm News | December 15, 2023

Webcast: M&A Insights – How to Use CVRs to Bridge Valuation Gaps, DOJ Self-Disclosure Guidelines for M&A, and Shareholder Activism Update

Join us for a 30-minute briefing covering several M&A practice topics. The program is the fourth in a series of quarterly webcasts designed to provide quick insights into emerging issues and practical advice on how to manage common M&A problems.

Webcasts | December 6, 2023

IRS and Treasury Issue Proposed Investment Tax Credit Regulations for Energy Property

Our lawyers provide background on the investment tax credit for energy property, summarize the proposed regulations issued by the IRS and Treasury, and share key implications for taxpayers.

Client Alert | December 1, 2023

Tax Court Holds That Non-U.S. Fund Is Engaged in a U.S. Trade or Business

The Court’s decision raises important considerations for asset managers, non-U.S. funds, and other non-U.S. persons that invest in the United States.

Client Alert | November 22, 2023

Disproportionate S Corporation Rollovers: Lindsey Buckingham Was Right

New York partner Eric Sloan and associate James Jennings are the authors of "Disproportionate S Corporation Rollovers: Lindsey Buckingham Was Right" published by Tax Notes Federal on November 13, 2023. 

Article | November 13, 2023

Who’s Who Legal Recognizes Four Gibson Dunn Partners in Corporate Tax 2023

Four Gibson Dunn partners were recognized in Who’s Who Legal’s Corporate Tax 2023 guide.

Firm News | November 7, 2023

Gibson Dunn Ranked in Chambers UK 2024

Gibson Dunn was recognized with seven firm and 18 individual rankings in the 2023 edition of Chambers UK. The firm was recognized in the categories.

Firm News | October 19, 2023

Gibson Dunn Ranked in The Legal 500 UK 2024

Gibson Dunn earned 21 practice area rankings in the 2024 edition of The Legal 500 UK. 

Firm News | October 4, 2023

Gibson Dunn Named Tax and Trusts Law Firm of the Year at the ALB Hong Kong Law Awards 2023

Asian Legal Business named Gibson Dunn the “Tax and Trusts Firm of the Year” at the ALB Hong Kong Law Awards 2023. The awards recognize the exceptional performance of private practitioners and in-house counsel in Hong Kong.

Firm News | September 18, 2023

IRS and Treasury Issue Proposed Regulations Providing Guidance on Prevailing Wage and Apprenticeship Requirements Applicable to Clean Energy Credits

Our lawyers review proposed regulations issued by the U.S. IRS and Treasury providing guidance on prevailing wage and apprenticeship requirements applicable to clean energy credits.

Client Alert | September 6, 2023

Gibson Dunn Ranked in World Tax 2024

World Tax, International Tax Review's annual guide to the world's leading tax advisory practices, has recognized Gibson Dunn in eight categories in its 2024 edition.

Firm News | August 30, 2023

Bottom Dollar Partnership Guarantees Are Falling Off A Cliff

Because of an expiring transition rule, a partner that currently relies on a “bottom dollar guarantee” to support an allocation of liabilities may be required to recognize gain unless that partner takes action before October 4, 2023. Our lawyers provide a brief overview and discussion of the applicable Treasury regulations and describe the action that should be taken before October 4.

Client Alert | August 29, 2023

11 Gibson Dunn Lawyers Named Lawyers of the Year for 2024

Best Lawyers® named 11 Gibson Dunn lawyers as the 2024 Lawyer of the Year in their respective practice areas and cities.

Firm News | August 17, 2023

Corporate Tax 2023: United Kingdom

London partner Sandy Bhogal and associates Bridget English, Sophie Walsh and Isabella Fladée are the authors of the "United Kingdom" chapter in Global Legal Insights - Corporate Tax 2023, published by Global Legal Group in July 2023.

Article | July 25, 2023

Corporate Tax 2023: USA

New York partner Eric Sloan, New York of counsel Jennifer Sabin and Washington, D.C. associate Jennifer Fitzgerald are the authors of the "USA" chapter in Global Legal Insights - Corporate Tax 2023, published by Global Legal Group in July 2023. 

Article | July 25, 2023

Webcast: New Rules for Buying and Selling Clean Energy Tax Credits

With corporations now able to purchase clean energy tax credits, Gibson Dunn partners Mike Cannon and Matt Donnelly will walk you through the credits available for purchase, the process for purchasing credits, the issues that buyers and sellers should address in negotiating credit sales, and emerging market developments related to the new rules for selling credits.

Webcasts | July 18, 2023

Webcast: Stock Buybacks: What You Need to Know (and Disclose) Following Adoption of the SEC’s New Rules

In this briefing, our lawyers cover key SEC rule changes that will significantly impact the timing, manner and nature of the disclosures required for company share repurchases, including nuanced interpretive issues and tax implications.

Webcasts | July 11, 2023

Gibson Dunn Adds Leading Tax Lawyer Greg Nelson in Houston

Gibson, Dunn & Crutcher LLP is pleased to announce that Greg Nelson has joined the firm as a Senior Counsel.

Press Releases | July 10, 2023

Gibson Dunn Advises EQT Exeter on the Formation of EQT Exeter Industrial Value Fund VI

Gibson, Dunn & Crutcher LLP advised EQT Exeter on the formation of EQT Exeter Industrial Value Fund VI, which closed on $4.9 billion of capital commitments. 

Firm News | July 7, 2023