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News & Publications
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Tax Transactions and Tax Controversy Update: Proposed regulations regarding application of foreign base company sales income rules to contract manufacturing arrangements (29 February 2008) |
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Client Alert: Stoneridge Investment Partners v. Scientific-Atlanta, Inc., No. 06-43 (15 January 2008) |
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Client Alert: Modifications of Securitized Subprime Mortgage Loans (21 December 2007) |
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Section 954(h) Active Finance Exceptions (12 December 2007) |
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Client Alert - IRS Narrows Definition of "Liquid Hydrocarbons Derived from Biomass" (20 November 2007) |
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Presentation: State and Local Tax Planning and Strategies for Mergers & Acquisitions (24 October 2007) |
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New Protocol to US-Canada Tax Treaty Would Eliminate Withholding Tax on Interest Payments(25 September 2007) |
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Tax Transactions Update: Temporary and Proposed Regulations Under Section 883 (16 July 2007) |
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Tax Transactions Practice Update: IRS Challenges Claims that Certain Capital Gain Dividends Received by Foreign Government Investors from REITs or RICs are Not Subject to US Tax (25 June 2007) |
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State Tax Risk, Opportunity and Defense in a FIN 48 World (19 June 2007) |
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134 Mayer Brown Lawyers Listed in Chambers USA Guide to Leading Business Lawyers (6 June 2006) |
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Larry Langdon: Career Commitment to ADR Has Paid Off - Outside the Courtroom (February 2006) (Published by: Moritz Law Alumni Relations) |
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Taxation of Investments into German Real Estate (January 2006) |
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Valuing Stock for Continuity of Interest in Section 368 Reorganizations (8 December 2005) |
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Treas. Reg. § 1.951-1(e) Determination of Pro Rata Share (20 October 2005) |
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Tax Update: New Circular of German Ministry of Finance regarding Thin Capitalization Rules (August 2005) |
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U.S. Senate Tax Counsel Fred Hartman Joins Mayer Brown (26 July 2005) |
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Mayer Brown Memorandum to Our Clients on IRS Circular 230
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American Jobs Creation Act of 2004 - Tax Provisions Relating to Shipping Income, Taxation Update (November 2004)
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American Jobs Creation Act of 2004 - Tax Provisions Relating to Shipping Income, Taxation Update (November 2004)
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International Comparative Legal Guide to: Corporate Tax 2005 (June 2004) (This article first appeared in International Comparative Legal Guide to: Corporate Tax 2005 published by the Global Legal Group) |
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Robert E. Glennon Joins Mayer Brown's Washington, D.C. Practice (15 January 2004) |
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The New School of Audit Effectiveness: A Report and Evaluation of the Strategies, Tools and Tax Administration Techniques of the Large and Mid-Size Business Division of the IRS (October/November 2003) |
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Attorneys for Foreign Shipping Firms Differ in Reactions to Ship, Aircraft Rules (9 September 2003) Reproduced with permission from Daily Tax Report, No. 174, pp. G-6 - G-7 (September 9, 2003). Copyright 2003 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com |
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Proposed Tax Regulations To Clarify Capitalization vs. Deduction Issue, Taxation Update (January 2003) |
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The 2001 Tax Act -- A Vanishing Act
C. Wells Hall III Interviewed by Jerald David August, Reprinted from the January / February 2002 Issue of Business Entities |
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Overview
The breadth of Mayer Brown's tax practice is matched by few other law firms. We currently have more than 100 tax lawyers in ten offices worldwide. Chambers and Partners recently described our practice as having outstanding strengths in both tax controversy and planning.
Our tax practice covers every aspect of corporate, partnership, and individual taxation in the United States and in Europe, including taxation of cross-border transactions and state and local issues. It comprises specialized subpractices in transactions, consulting and planning, audits, administrative appeals and litigation, and government relations. Our clients include 65 of the Fortune 100 companies.
Ranked among the top ten law firms in the world, Mayer Brown has lawyers in the Americas, Asia and Europe.
Our transactional and consulting tax practices include partners located in five United States offices, the United Kingdom, Germany, and France. Our practice covers nearly every type of business transaction and restructuring, and is internationally recognized as one of the leaders in a number of areas.
Corporate Mergers and Acquisitions
Mayer Brown has had representation in many major corporate mergers and acquisitions, and is regularly involved in a wide range of domestic and cross-border restructuring and related planning.
European Practice
In Europe, our tax practice is widely based. We have considerable experience in corporate mergers and demergers, corporate structurings, financial matters, real estate transactions, and investment funds both retail and institutional. See below for the German tax practice.
Government Relations
We regularly work with the IRS national office, the Treasury Department, and the staff of tax writing committees with respect to regulations, legislation, private letter rulings, closing agreements, and similar matters.
Bankruptcy and Financial Restructuring
We represent lenders, equity investors, and debtors in complex financial restructuring transactions and workouts, both pursuant to bankruptcy proceedings and out-of-court agreements.
Banking, Financial Products, and Securitization
We regularly represent many of the world's largest banks in connection with complex financing transactions and planning, and have one of the leading securitization, financial products and investment fund practices in the world.
Insurance
We have a leading offshore insurance practice in the United States representing both insurers and reinsurers. Our work includes organization and operation of these companies as non-CFCs and non-PFICs, as well as addressing insurance industry-specific questions.
International
We have a leading international tax transactional, planning and consulting practice, focusing on international M&A, restructurings, intangible migration, transfer pricing, and minimization of worldwide effective tax rates for US- and non US-based multinationals.
Leasing
Our leasing practice is one of the predominant leasing practices in the United States with substantial presence in both domestic and cross-border transactions.
Real Estate
Our tax-related practice in the real estate area includes representation of public and private real estate investment trusts, institutional real estate investors, real estate fund managers and developers, and structuring cross-border real estate investment.
Mayer Brown's tax controversy and transfer pricing practice is one of the most active in the United States. The practice consists of 18 partners devoted almost exclusively to tax controversy and transfer pricing matters. For more information, click here.
German Office Practice
The German tax group of Mayer Brown advises on all significant business and commercial related areas of tax law. A focal point of our work is the tax efficient structuring of M& A transactions, structuring and restructuring of companies or corporate groups and general advice with respect to complex tax questions.
Due to the clearly increasing importance of the banking law division for the firm in Germany, the tax practice group has been formed to continue to support capital market projects. This also includes advice in connection with ABS and NPL transactions, structured financing, cross border leasing and tax optimized formation of and acting for funds.
For clients with foreign interests, the legal advice by our German tax group in foreign transaction tax law is especially important. This includes the optimal tax formation of service and supply relationships within corporate groups as well as in matters concerning the Double Tax Conventions. Our local expertise, international network and contacts with tax consultants and certified public accountants enable us to provide our clients with the best possible comprehensive advice and a flexible approach to provide tax solution.
The German lawyers at Mayer Brown specializing in tax law advice are also qualified as tax consultants (Steuerberater) to maintain our high quality on tax advice. We advise on national and international tax law and can draw on the expertise of over 45 tax lawyers in our offices in the US, UK and France who are specialized in a range of complex tax issues.
Speaking Engagements
Look at this Mess! A Practical Look at Entity Rationalization
Rafic Barrage and Jason Bazar Tax Executive Institute – Mid-Year Conference 2008 Washington, DC April 8, 2008
National Local and State Tax Update Richard A. Leavy Tax Executive Institute – Mid-Year Conference 2008 Washington, DC April 7, 2008
Current Developments International Tax
Jason Bazar (Panelist) ABA Tax Section Washington, DC May 9, 2008
Special Rules Under Subpart F for Active Finance Income Jason Bazar Atlas Seminar on U.S. Tax Planning for CFC's Under Subpart F Philadelphia, PA June 25, 2008
Developments, Themes and Theories in Stock Basis Timothy C. Sherck (Panel Moderator) Sixtieth Annual Federal Tax Conference, University of Chicago Chicago, IL November 9, 2007
State and Local Taxation: Entity and Transactional Nexus Richard A. Leavy Advanced Interstate Tax Seminar Stamford, CT October 16, 2007 View Presentation
Tax-Free & Partially Tax-Free Acquisitive Reorganizations
Timothy C. Sherck Practicing Law Institute Chicago, IL October 11, 2007
Selected Current Issues in M&A James R. Barry PLI – Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings Chicago, IL October 11, 2007
Tax Planning and Strategies for Mergers & Acquisitions: State and Local Issues
Paul DiSangro and Richard A. Leavy Tax Executive Institute – Chicago Chapter Chicago, IL July 26, 2007 View Presentation
Multistate Developments and Controversies
Richard A. Leavy Institute of International Bankers – Annual Tax Seminar and 22nd Annual Spring Tax Day New York, NY June 19, 2007
Inbound Financing & Acquisition Planning - Recent Developments
James R. Barry Organization for International Investment 2007 Tax Conference Aventura, FL
Permanent Developments: New Developments Impacting Inbound Companies Rafic H. Barrage Aventura, FL April 26, 2007 Enhancing the Value of Deferral: Part I – Base Company Planning Jonathan A. Sambur ATLAS – US Tax Planning for CFCs Under Subpart F Chicago, IL April 13, 2007 Section 883 and Treaties – Stock Ownership and Substantiation Requirements and Treaty Shopping Restrictions Outbound Transfers to Controlled Foreign Corporations Rafic H. Barrage and Kenneth Klein ATLAS: US Tax Aspects of International Shipping Las Vegas, NV March 2, 2007 Considerations in Forming a New Company C. Wells Hall, III Business Law Section Annual Meeting, North Carolina Bar Association Pinehurst, NC February 15, 2007 View Presentation When “Acquirer” or “Target” is Spelled with an “S” – Special Considerations for S Corporations in Mergers and Acquisitions C. Wells Hall, III January 25, 2007 View Presentation
Introduction to U.S. International Tax Rafic H. Barrage ATLAS: How the US Subpart F Rules Operate Washington, DC December 5, 2006 Tax Considerations of Transfers to and Distributions from the C or S Corporation C. Wells Hall, III 52nd Tax Conference, The College of William & Mary Williamsburg, VA November 16 and 17, 2006 View Presentation
Selected Current Issues in M&A James R. Barry PLI – Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings Chicago, IL November 16, 2006 The Mixed up World of Pseudo Pass-Throughs James R. Barry University of Chicago Law School 59th Annual Federal Tax Conference Chicago, IL November 11, 2006 Active Finance Exceptions Under Subpart F Jason S. Bazar Office of Mayer Brown LLP New York, NY September 18, 2006 Section 7874 Inversion Transactions Rafic Barrage & Jonathan Sambur Office of Mayer Brown LLP Washington, DC June 15, 2006 View Presentation
Recent Developments in Cross Border Financing James R. Barry Organization for International Investment 2006 Tax Conference Santa Fe, NM May 11, 2006 Corporate Reorganizations, Spin Offs, and Mergers & Acquisitions: Current Tax Planning Issues Timothy C. Sherck 25th Annual Federal Tax Institute, Chicago-Kent College of Law Chicago, IL April 20, 2006 View Presentation
Pre Conference Workshop James R. Barry Strategic Research Institute: 4th Annual Institutional Real Estate Investing Forum (IREIF) Scottsdale, AZ January 29, 2006
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