ABOUT THE FIRM
Over the past four decades, our attorneys have developed considerable experience in the structuring, negotiation, documentation and implementation of a broad range of international and domestic transactions, including transactions involving corporate acquisitions, divestitures (including spin‑offs), reorganizations, restructurings and financings; pooled investment funds; financial instruments; joint ventures, partnerships and limited liability companies; complex entertainment and media matters; nonqualified employee compensation arrangements; debt workouts; and real estate development and investments, as well as negotiating treaties and other international agreements on behalf of foreign governments.
In certain cases, creating the optimal structure for our clients' businesses and transactions requires approaching a government agency for a ruling or clearance or a modification to a U.S. Treasury Department regulation, a statutory provision or an income tax convention between the United States and another country. Due to our approach to these types of matters and our reputation with the various government agencies, we have been able to secure extremely favorable results for our clients in these matters.
We have also resolved favorably for our clients numerous major disputes with various tax agencies in the United States potentially involving very substantial dollar amounts and have on a number of occasions worked with and assisted our clients' non‑U.S. counsel in connection with the resolution of tax disputes with foreign governments. In our experience, most tax disputes, if properly handled, are capable of being resolved to the satisfaction of the parties at either the audit or administrative appeal stages without resort to formal litigation. Nonetheless, there are cases that require litigation before a dispute can be resolved. Where litigation is necessary, we are fully capable of litigating an adverse determination by a U.S. taxing authority in the appropriate court or tribunal. Our approach to the resolution of tax disputes and our reputation in the various tax agencies has enabled us to obtain extremely favorable results for our clients in these matters as well.
Whatever the nature of our clients' transactions and problems, our goal is to add value by crafting creative tax and business solutions. As a result of our success in achieving this goal, the firm is called upon to advise clients in a broad range of international matters. We should add that our views concerning the legal aspects of fiscal matters are well respected internationally, as indicated by our attorneys' frequent speaking engagements and publications. A listing of certain publications authored by our attorneys is available upon request.
The skills and experience of the firm's attorneys complement one another and permit the firm to offer a full range of legal services. In addition, we work extensively with non-U.S. counsel in various parts of the world and, accordingly, have the ability to draw on their expertise in connection with our clients' non‑U.S. matters.