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.

RECENT PUBLICATIONS

Gibson Dunn Ranked in the 2021 UK Legal 500

-October 5, 2020

UK Government Announces Its ‘Winter Economy Plan’

-September 24, 2020

World Tax Recognizes Sandy Bhogal and Elaine Chen

-September 24, 2020

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

-September 1, 2020

Corporate Tax 2020 – United Kingdom

-August 4, 2020

Tax Partner Pamela Lawrence Endreny Joins Gibson Dunn in New York

-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

COVID-19, the CARES Act and Tax Planning for Real Estate and Passthrough Businesses

-April 20, 2020

UK Tax Quarterly Update – The UK Digital Services Tax

-April 9, 2020

Gibson Dunn Deal Receives Honorable Mention in Asian-Mena Counsel Magazine

-April 3, 2020

UK Tax Quarterly Update – April 2020 Budget Special

-April 3, 2020

Tax Relief in the CARES Act

-March 27, 2020

IRS Extends Income Tax Return Filing and Payment Deadlines from April 15 to July 15; Many U.S. States Follow Suit

-March 27, 2020

Tax-Favored Financial and Other Assistance to Employees in the Face of COVID-19

-March 26, 2020

Gibson Dunn Earns 155 Rankings from Chambers Global 2020

-March 5, 2020

David Rubin Wins International Tax Student Writing Competition

-March 3, 2020

Maryland Introduces New Carried Interest Tax Legislation

-February 27, 2020

Guaranteed Payments and Interest: Why Treasury Is Overreaching

-February 6, 2020

Who’s Who Legal Recognizes 15 Gibson Dunn Partners in Litigation, Corporate Tax and Private Funds

-January 30, 2020

Tax in 2019. Year in Review. A Financial Services Perspective.

-January 27, 2020

What Impact Will Brexit Have on Derivative Benefits Test Under U.S. Double Tax Treaties?

-January 17, 2020

2019 Year-End German Law Update

-January 10, 2020

Taxing the Digital Economy

-December 18, 2019

Gibson Dunn Promotes 13 Lawyers to Partnership

-November 20, 2019

IRS Updates U.S. Retirement Plan COLAs for 2020

-November 7, 2019

Treasury Releases Guidance on the Transition from LIBOR to Other Reference Rates

-October 16, 2019

IRS Releases Guidance on Taxation of Virtual Currencies

-October 10, 2019

Gibson Dunn Adds Tax Partner Ben Fryer in London

-October 7, 2019

Gibson Dunn Ranked in the 2020 UK Legal 500

-October 4, 2019

UK Supreme Court Decides Suspending UK Parliament Was Unlawful

-September 24, 2019

Gibson Dunn Lawyers Recognized in the Best Lawyers in America® 2020

-August 15, 2019

New UK Prime Minister – what has happened?

-July 26, 2019

Digital Services Taxes May Violate Investment Treaty Protections

-July 24, 2019

Tell Me It’s Over: Tax Year Endings and M&A Transactions

-July 10, 2019

Best Lawyers in France 2020 Recognizes 16 Gibson Dunn Attorneys

-July 1, 2019

Can the U.K. Digital Services Tax Address the Digital Economy?

-June 26, 2019

Taxing the Digital Economy and Digital Service Tax Proposals Impacting the United Kingdom and the European Union

-June 20, 2019

Four Gibson Dunn Partners Recognized in Who’s Who Legal 2019 in Tax, Life Sciences and Insurance

-June 18, 2019

UK Nationalisation – Investment Treaties can offer opportunities to reorganise now to protect valuations

-May 9, 2019

IRS Issues Additional Guidance on Investing in Opportunity Zones

-April 22, 2019

Gibson Dunn Ranked in Legal 500 EMEA 2019

-April 19, 2019

Supreme Court Holds That Payments For Lost Wages Are Taxable “Compensation” Under The Railroad Retirement Tax Act

-March 5, 2019

Staking Out New Territory: Taxation of Proof-of-Stake Protocols

-January 28, 2019

2018 Year-End German Law Update

-January 11, 2019

UK Real Estate Tax – A New Landscape For Investors

-December 18, 2018

Taxing the Digital Economy

-November 21, 2018

The Impact on MNCs

-November 5, 2018

Gibson Dunn Ranked in Chambers UK 2019

-November 2, 2018

U.S. News – Best Lawyers® Awards Gibson Dunn 132 Top-Tier Rankings

-November 2, 2018

Webcast: Spinning Out and Splitting Off – Navigating Complex Challenges in Corporate Separations

-October 31, 2018

IRS Provides Much Needed Guidance on Opportunity Zones through Issuance of Proposed Regulations

-October 22, 2018

Why We Think the UK Is Heading for a “Soft Brexit”

-October 10, 2018

The 100 Percent Tax-Exempt Use Property Trap: Funds Beware

-September 3, 2018

IRS Issues Initial Selective Guidance on New Section 162(m) Provisions, including Transition Rules

-August 29, 2018

Eric Sloan Selected as American Bar Association Tax Section Vice Chair

-August 7, 2018

Who’s Who Legal Recognizes Nine Gibson Dunn Partners

-August 1, 2018

The Impact on MNCs

-July 13, 2018

The Politics of Brexit for those Outside the UK

-July 12, 2018

Gibson Dunn Receives Chambers USA Excellence Award

-May 25, 2018

Brexit – converting the political deal into a legal deal and the end state

-March 12, 2018

IRS Issues First “Required Amendments List” for Tax-Qualified Retirement Plans Under New Program

-February 1, 2018

The Overhaul of France’s Tax Laws Has Been Enacted -What Will the 2018 Finance Act Change?

-January 17, 2018

2017 Year-End German Law Update

-January 7, 2018

Taxing International Investors in UK Real Estate

-January 1, 2018

Houston, We have New Tax Rates – Guiding Oil and Gas Companies Through Tax Reform

-December 21, 2017

Brexit – Initial deal agreed

-December 8, 2017

What House And Senate Tax Bills Mean For Oil And Gas Cos.

-December 7, 2017

Black and Grey: The EU Publishes Its Lists of Tax Havens

-December 7, 2017

International Investors to Be Liable to UK Tax on Capital Gains Derived from UK Real Estate from 2019

-November 24, 2017

Potential Changes in Taxation of Executive Compensation and Employee Benefits Under the Proposed House Tax Legislation

-November 8, 2017

House GOP Releases Major Tax Reform Bill

-November 3, 2017

UK Criminal Finances Act 2017: New Corporate Facilitation of Tax Evasion Offence – Act Now to Secure the Reasonable Prevention Procedures Defence

-September 29, 2017

Internal Revenue Service Announces Relief for Southeast Texas Due to Hurricane Harvey

-September 5, 2017

French Market Update – July 2017

-July 20, 2017

California Supreme Court Upholds Los Angeles County’s Interpretation of Documentary Transfer Tax Act

-July 10, 2017

What the UK Election Result Means for Brexit

-June 9, 2017

What the UK’s Snap General Election Means for Brexit

-April 21, 2017

UK Government Triggers Article 50

-March 29, 2017

Update on German Taxation Developments Regarding Management Equity Programs

-February 2, 2017

UK Supreme Court Rules Parliament Must Hold Vote on Article 50

-January 24, 2017

2016 Year-End German Law Update

-January 13, 2017

The Trump Presidency: Selected Initial Observations and Considerations

-November 15, 2016

IRS Issues Final and Proposed Regulations Addressing Partnerships and Section 956 and the Active Rents and Royalties Exception

-November 11, 2016

UK High Court Rules That Parliament Must Vote on Triggering Article 50 Process for Brexit

-November 3, 2016

IRS Updates U.S. Retirement Plan COLAs for 2017

-November 1, 2016

Brexit – UK Government Sets Out Process to Leave EU by 2019

-October 3, 2016

Brexit – What We Are Hearing

-September 22, 2016

The Gift of Worldwide Taxation

-September 13, 2016

IRS Releases Final Regulations Clarifying the Definition of Real Property for REITs

-September 9, 2016

IRS Issues Temporary Regulations for Early Election into New Partnership Audit Rules

-August 8, 2016

Is It Still Possible to Implement Tax-Free Step-Up of Real Estate Assets Held Through a French SCI?

-July 25, 2016