Tax

LEADERS

Overview

The Tax Practice Group provides large multinational corporations, publicly traded and private companies, sovereign wealth funds, investment funds, partnerships, joint ventures and startups with state-of-the-art tax advice.

The Tax Practice Group’s transactional practice provides tax advice to clients in connection with a broad range of business transactions and investments, including:

  • Taxable and tax-free mergers
  • Acquisitions
  • Reorganizations and dispositions (including spin-offs and split-offs)
  • Insolvency restructurings
  • Business combinations
  • Capital markets offerings
  • Investment fund formation
  • Infrastructure investments
  • Real estate acquisition and disposition
  • Specialized investment vehicles, including master limited partnerships and real estate investment trusts

Within the United States, the U.S. members of the Tax Practice Group have developed significant knowledge and capabilities in all aspects of U.S. income taxation.  Our lawyers work with clients on day-to-day planning, allowing us to detect tax concerns and opportunities early on and to devise and implement innovative, practical solutions for best possible results.  We advise clients on transactional, international and tax litigation and administrative matters.  Our global reach allows the Tax Practice Group to advise U.S. companies on European and Asian tax matters, covering both direct and indirect taxes.

Within Gibson, Dunn & Crutcher’s non-U.S. offices, our tax lawyers are qualified to practice under the laws of the United States, England and Wales, France and Germany.  The Tax Practice Group’s international reach permits a full range of tax services to corporations, partnerships, financial institutions, investment funds, sovereign wealth funds and other non-U.S. entities.  The Tax Practice Group also advises on structuring and negotiating cross-border acquisitions, dispositions and other business combinations as well as inbound and outbound investments.  We also advise on the taxation of international employment engagements, including employee incentive arrangements.

The Tax Practice Group represents clients in litigation and administrative inquiries, audits, appeals proceedings and tax litigation relating to U.S. federal and state and European tax issues.  In addition, we provide Gibson Dunn’s outstanding team of internationally known litigators with advice on the taxation of various litigation-related issues, including the tax implications of settlements and verdicts, as well as the corresponding reporting obligations.

Experience

Many of our transactions are private and cannot be disclosed.  Recent examples of public transactions in connection with which the Tax Practice Group assisted clients with innovative tax strategies include the following:

  • AECOM, in its $4 billion acquisition of URS Corporation.
  • Vivendi SA in its tax-free sale of shares in Activision Blizzard Inc.
  • A consortium of Chinese companies in its acquisition of OmniVision Technologies Inc. for nearly $2 billion.
  • Tri Pointe Homes in its $2.7 billion acquisition of Weyerhauser’s home-building division by means of a “reverse Morris Trust” transaction.
  • Robert Bosch GmbH in its €3 billion acquisition of a 50% stake in Bosch BSH GmbH from Siemens AG.
  • Hewlett-Packard Company in its $2.7 billion acquisition of Aruba Networks, a provider of enterprise wireless LAN and edge access networking equipment.
  • Lion Gables Apartment Fund L.P. in its $3.2 billion sale of Gables Residential Services, a privately held real estate investment trust (REIT) that owns, develops, and manages apartment complexes, to a group of investors led by Clarion Partners.
  • Coty in connection with its acquisition of the international cosmetics group Bourjois from French haute couture and cosmetics group Chanel for a consideration of approximately 15.43 million shares of Coty’s Class A common stock.
  • Doremi Labs, the leading provider of digital cinema video playback solutions, in connection with Dolby Laboratories Inc.’s acquisition of Doremi Labs and French distributor Highlands Technologies SAS.

For additional information, please visit our global Tax Controversy and Litigation practice page.

RECENT PUBLICATIONS

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

-May 20, 2024

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

-May 6, 2024

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

-April 26, 2024

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

-April 11, 2024

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

-April 8, 2024

Gibson Dunn Ranked in Legal 500 EMEA 2024

-March 27, 2024

Gibson Dunn Ranked in Chambers Europe 2024

-March 14, 2024

Tax Partner Benjamin Rapp to Join Gibson Dunn in Germany

-February 8, 2024

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

-February 2, 2024

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

-January 11, 2024

The State of Louisiana Is Granted Primacy Over Class VI Wells

-January 8, 2024

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

-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

-December 19, 2023

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

-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

-December 6, 2023

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

-December 1, 2023

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

-November 22, 2023

Disproportionate S Corporation Rollovers: Lindsey Buckingham Was Right

-November 13, 2023

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

-November 7, 2023

Gibson Dunn Ranked in Chambers UK 2024

-October 19, 2023

Gibson Dunn Ranked in The Legal 500 UK 2024

-October 4, 2023

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

-September 18, 2023

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

-September 6, 2023

Gibson Dunn Ranked in World Tax 2024

-August 30, 2023

Bottom Dollar Partnership Guarantees Are Falling Off A Cliff

-August 29, 2023

11 Gibson Dunn Lawyers Named Lawyers of the Year for 2024

-August 17, 2023

Corporate Tax 2023: United Kingdom

-July 25, 2023

Corporate Tax 2023: USA

-July 25, 2023

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

-July 18, 2023

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

-July 11, 2023

Gibson Dunn Adds Leading Tax Lawyer Greg Nelson in Houston

-July 10, 2023

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

-July 7, 2023

IRS and Treasury Issue Proposed Regulations Providing Initial Guidance on Direct Payments for Clean Energy Credits

-June 29, 2023

IRS and Treasury Issue Proposed and Temporary Regulations Providing Initial Guidance on Transferability of Clean Energy Credits

-June 21, 2023

New IRS Guidance on Acceptance of Advance Pricing Agreement (APA) Submissions and Increased Pre-Submission Review

-May 25, 2023

IRS and Treasury Issue Notice 2023-38 Providing Initial Guidance on “Domestic Content” for ITC- and PTC-eligible Projects

-May 17, 2023

IRS and Treasury Release Update to Notice 2023-29 on “Energy Community” Bonus for ITC- and PTC-eligible Projects

-April 12, 2023

Gibson Dunn Ranked in Chambers Europe 2023

-March 16, 2023

Supreme Court Holds That Bank Secrecy Act Imposes Single Penalty For Nonwillful Failure To File Timely, Accurate Annual Report Of Foreign Bank And Financial Accounts

-February 28, 2023

Gibson Dunn Ranked in 2023 Chambers Greater China Region Guide

-January 13, 2023

Who’s Who Legal Recognizes 39 Gibson Dunn Partners in its Inaugural Thought Leaders USA Guide

-January 9, 2023

IRS and Treasury Issue Interim Guidance Addressing the Corporate Alternative Minimum Tax

-January 6, 2023

IRS and Treasury Issue Proposed Regulations Narrowing Domestically Controlled REIT Qualification Test and Revising Section 892 Exemption, as Well as Final Regulations Relating to Qualified Foreign Pension Funds

-January 4, 2023

Who’s Who Thought Leaders – Global Elite 2023 Recognizes Eleven Gibson Dunn Partners

-January 4, 2023

IRS and Treasury Issue Interim Guidance on New Stock Buyback Excise Tax

-January 3, 2023

UK Tax Update – December 2022

-December 22, 2022

IRS and Treasury Issue Proposed Regulations on Consolidated Group Ownership of CFC Stock for Certain Purposes

-December 16, 2022

Proposed U.S. Foreign Tax Credit Rules Provide Relief for Certain Taxpayers and Ideas for Others

-December 1, 2022

Measure ULA: New Transfer Tax on Los Angeles Residential and Commercial Real Property Sales Over $5 Million

-November 14, 2022

Who’s Who Legal Recognizes Four Gibson Dunn Partners in Corporate Tax 2022

-October 28, 2022

Gibson Dunn Ranked in Chambers UK 2023

-October 20, 2022

Euromoney’s Rising Star Awards 2022 Recognizes 16 Gibson Dunn Partners

-October 12, 2022

Gibson Dunn Ranked in The Legal 500 UK 2023

-September 29, 2022

Gibson Dunn Ranked in World Tax 2023

-September 29, 2022

The Inflation Reduction Act Includes Significant Benefits for the Carbon Capture Industry

-August 16, 2022

Update: Senate Passes Revised Version of Inflation Reduction Act of 2022; Carried Interest Changes Omitted and Tax on Corporate Stock Buybacks Added

-August 10, 2022

Inflation Reduction Act of 2022 Would Modify the Tax Treatment of Carried Interests, Include a Corporate Minimum Tax, and Expand Clean Energy Tax Incentives

-July 29, 2022

Corporate Tax 2022: United Kingdom

-July 27, 2022

Expert Guides Recognizes Four Gibson Dunn Partners in Tax

-July 8, 2022

Introduction of Corporate Tax in the UAE

-May 12, 2022

UK Tax Quarterly Update – February 2022

-February 1, 2022

How Justices May Interpret Statutory Time Bar In Tax Context

-January 24, 2022

2021 Year-End German Law Update

-January 13, 2022

Gibson Dunn Ranked in The Legal 500 Asia Pacific 2022

-January 13, 2022

Gibson Dunn Ranked in 2022 Chambers Greater China Region Guide

-January 12, 2022

Webcast: 2022 Tax Legislative, Regulatory and Enforcement Update

-January 11, 2022

The Potential for Tax Enforcement Through Subregulatory Guidance

-December 13, 2021

Gibson Dunn Adds Tax Controversy Group, Led by Sanford Stark, in Washington, D.C.

-November 15, 2021

Who’s Who Legal 2021 Guides Recognize Ten Gibson Dunn Partners

-November 5, 2021

Gibson Dunn Promotes 27 Lawyers to Partnership

-November 4, 2021

U.S. House Ways and Means Committee Proposes Substantial Extension and Expansion of Clean Energy Tax Incentives

-October 13, 2021

Gibson Dunn Ranked in the 2022 UK Legal 500

-October 7, 2021

Who’s Who Legal 2021 Recognizes Gibson Dunn Partners in Thought Leaders – Global Elite

-September 28, 2021

Law360 Names Six Gibson Dunn Partners as 2021 MVPs

-September 8, 2021

Tax Partner Matt Donnelly Joins Gibson Dunn in D.C.

-September 1, 2021

Senate Finance Committee Chairman Ron Wyden (D-OR) Introduces the “Ending The Carried Interest Loophole Act” That Would Require Current Ordinary Income Inclusions

-August 10, 2021

Corporate Tax 2021 – United Kingdom

-August 4, 2021

Zum Anpassungsbedarf bei Gewinnabführungsverträgen

-June 28, 2021

Biden Administration Releases Fiscal Year 2022 Budget, Together With a “Greenbook” Providing Detailed Descriptions of Proposed Changes to Federal Tax Law and Accompanying Revenue Estimates

-May 29, 2021

UK Tax Quarterly Update – May 2021

-May 24, 2021

Taxation of Crypto Assets: United Kingdom

-May 13, 2021

Former IRS Chief Counsel Michael Desmond Joins Gibson Dunn’s Los Angeles and D.C. Offices

-May 3, 2021

Evaluating Creditor Continuity of Interest: A 10-Step Process

-April 13, 2021

The Clean Energy Revolution: Renewable Energy Tax Incentives and Issues

-April 12, 2021

New York Adopts LIBOR Legislation

-April 8, 2021

The End Is Near: LIBOR Cessation Dates Formally Announced

-March 9, 2021

Who’s Who Legal 2021 Recognizes Gibson Dunn Partners in Arbitration, Tax and Competition

-January 14, 2021

2020 Year-End German Law Update

-January 14, 2021

DAC 6 Update: UK Narrows Scope of Mandatory Tax Reporting

-January 4, 2021

Real Estate Partnerships: The Basics and Some Technical Stuff

-December 23, 2020

UK Tax Quarterly Update – December 2020

-December 22, 2020

Gibson Dunn Ranked in the 2021 UK Legal 500

-October 5, 2020

Gibson Dunn Ranked in World Tax 2021

-September 29, 2020

World Tax Recognizes Sandy Bhogal and Elaine Chen

-September 24, 2020

UK Government Announces Its ‘Winter Economy Plan’

-September 24, 2020

Murphy Oil’s $2.127 billion Divestment of its Malaysian Operations to PTTEP Named Impact Deal of the Year by ITR

-August 31, 2020

Tax Partner Pamela Lawrence Endreny Joins Gibson Dunn in New York

-August 4, 2020

Corporate Tax 2020 – United Kingdom

-August 4, 2020

Jeff Trinklein and Sandy Bhogal Recognized in Tax Expert Guide 2020

-July 17, 2020

UK Tax Quarterly Update – July 2020

-July 16, 2020

Best Lawyers in Germany 2021 Recognizes 19 Gibson Dunn Attorneys

-June 26, 2020

Best Lawyers in France 2021 Recognizes 17 Gibson Dunn Attorneys

-June 25, 2020

Bankruptcy-Proximate Owner Shift? Loss Corporation Beware

-June 15, 2020

Covid-19, the CARES Act and Tax Planning for Real Estate and Passthrough Businesses — Part II

-May 22, 2020

Double Tax Benefits in the CARES Act

-May 18, 2020

Tax implications of benchmark reform: UK tax authority weighs in

-May 4, 2020

IRS Issues Notice Clarifying Expenses Funded with Proceeds of Small Business Administration Loans under Paycheck Protection Program

-May 1, 2020

Gibson Dunn Ranked in Legal 500 EMEA 2020

-April 30, 2020