Paul W. Oosterhuis
International and Corporate Tax Law
Paul W. Oosterhuis is the global head of Skadden’s Regulatory practices and represents clients on a wide range of international and domestic tax matters.
Mr. Oosterhuis has extensive experience in international mergers and acquisitions, post-acquisition integration transactions, spin-off transactions, internal restructurings and joint venture transactions. He also represents U.S. and non-U.S. multinational companies in nontransactional international tax planning and IRS controversy matters.
In international transactions, Mr. Oosterhuis has represented:
- Visa in its global restructuring and IPO;
- Schering-Plough Corporation in its acquisition of Organon N.V.;
- Alcatel S.A. in its combination with Lucent Technologies;
- Quiksilver in its acquisition of Rossignol SA;
- Yahoo! Inc. in the combination of its Chinese business with Alibaba.com Corporation; and
- Royal Dutch NV and Shell Transport Ltd. in their restructuring to form Royal Dutch Shell plc.
He also has represented numerous clients in internal restructuring and post-acquisition integration efforts, including Hewlett-Packard Company, Pfizer Inc., Eli Lilly, GlaxoSmithKline and IBM.
In addition to specific transactions, Mr. Oosterhuis regularly advises clients on international tax planning matters generally, including transfer pricing matters. He also represents clients in audits and appeals before the Internal Revenue Service and has negotiated, on behalf of clients, various advance pricing agreements, prefiling agreements and competent authority agreements. For example, he has advised The Bank of New York; Covidien, plc; GlaxoSmithKline; Hewlett-Packard Company; Intel Corporation; International Paper; NTL; Royal Dutch Shell; Cooper Industries; and Transocean. He also has served as outside tax counsel for the Pharmaceutical Research Manufacturers Association.
Mr. Oosterhuis has regularly been selected for inclusion in Chambers USA: America’s Leading Lawyers for Business, Chambers Global: The World’s Leading Lawyers for Business, Tax Directors Handbook and The Best Lawyers in America. He also was named Best Lawyers’ “2013 Washington, D.C. Litigation & Controversy - Tax Lawyer of the Year.”
J.D., Harvard University, 1973 (cum laude)
B.A., Brown University, 1969 (magna cum laude)
Legislation Attorney, Joint Committee on Taxation, U.S. Congress (1973-1976)
Legislation Counsel, Joint Committee on Taxation, U.S. Congress (1977-1978)
Adjunct Professor of Law, Georgetown University Law Center (1977-1983)
"The Evolution of U.S. International Tax Policy - What Would Larry Say?," Tax Notes International, June 26, 2006
"Check-The-Box Planning in Cross-Border Transactions," TAXES Vol. 83, No.3, (March 2005)
"International R&D and Technology Transfer Arrangements," TAXES, December 1995
"The Cost of Deferral's Repeal: If Done Properly, It Loses Billions," Tax Notes, February 8, 1993
"Musings on Rev. Rul. 91-5 and Its Implications for Section 304 Transactions," Tax Notes, March 18, 1991
"The Export Source Rule: An Age-Old Rule with a Dubious New Interpretation," Tax Notes, June 26, 1989
Co-Author, BNA Tax Management Portfolio, Research and Development Expenditures, 42-3rd T.M. (1987)