/sites/default/files/entity_pdf/International_Tax.pdf

International Tax

Members of the International Tax Group at Skadden have extensive experience in strategic tax planning and tax implementation issues associated with multijurisdictional, cross-border transactions. We also represent clients in cross-border tax controversies, including advising on transfer pricing and competent authority matters, and managing and resolving disputes arising from global, regional and bilateral business transactions. With tax attorneys resident in the United States, France, Germany and the United Kingdom, the firm is capable of providing advice in various jurisdictions on a multitude of issues. We are one of the few international law firms that provides a combination of both domestic and cross-border tax advice within the major European jurisdictions. For those jurisdictions in Europe in which we do not have attorneys resident or licensed, we have established a network of local counsel to whom we refer matters.

Skadden received two awards at the 2016 International Tax Review Americas Awards: Americas M&A Deal of the Year award for our work advising E. I. du Pont de Nemours and Company, and the Americas Technology and Telecom Tax Deal of the Year award for our role advising Broadcom. We were named among Law360’s Tax Groups of 2016 and ranked as a top-tier firm by Chambers Global 2017 and International Tax Review’s World Transfer Pricing 2017. Tax Directors Handbook repeatedly ranks Skadden in the top tier for international tax. The Tax Group and its members also are repeatedly named as leaders in their field in Chambers Global, Chambers USA, Chambers Europe and Legal 500.

Several attorneys in Skadden’s International Tax Group have extensive tax-related administrative and policy experience. Attorneys in our U.S. Tax Group have formerly held positions that include: assistant secretary for tax policy at the Treasury, Treasury international tax counsel, IRS commissioner, chief counsel of the IRS, IRS associate chief counsel (international), international tax counsel of the Congressional Joint Committee on Taxation and the U.S. competent authority on cross-border tax issues and treaties. Members of our European Tax Group sit on several U.K. revenue committees that consider key technical developments and help frame policy and legislation on tax issues.

Skadden’s international tax work includes structuring cross-border migrations acquisitions, divestitures, hybrid and other financings, and equipment leases and related financings; representing issuers and underwriters in U.S. and Euromarket offerings; creating multinational trusts; and advising on international joint ventures and international project financings in emerging markets. We also have substantial experience in post-acquisition restructuring, frequently teaming with the Big Four accounting firms. Our representations include legislative, administrative and policy work, treaty negotiations and interpretation, unilateral and bilateral advance pricing agreements, and private letter rulings relating to international aspects of major transactions. Frequently, our work involves novel and innovative types of transactions and new developments in changing areas of the law.

In addition, Skadden attorneys routinely advise clients in connection with international tax controversy matters, including transfer pricing, in all phases of the dispute resolution process (i.e., audits, appeals, mediation, arbitration, competent authority proceedings and litigation). Our transfer pricing practice advises multinationals on international structuring, disputes and APAs, and our competent authority practice covers a wide range of issues raised by double tax treaties.

Our tax attorneys also counsel international investors regarding their investments in U.S. ventures and international investment funds, as well as their tax treatment under U.S. laws and treaties.

The International Tax Group at Skadden, Arps has rendered international tax planning advice to a variety of clients, including Abercrombie & Fitch; Amazon; American Express; AstraZeneca; BlackRock; Covidien Ltd.; Daimler-Benz; Eaton Corporation; Eli Lilly; ExxonMobil; Fortress Investment Group; GlaxoSmithKline; Hasbro, Inc.; Hewlett-Packard Company; IBM; Johnson & Johnson; Liberty Mutual; McKesson Corporation; Merck: Merrill Lynch; MetLife; Pfizer Inc.; Royal Dutch Shell; Sara Lee Corporation; SwissRe; Transocean, Ltd.; Valeant Pharmaceutical; Visa, Inc.; and Yahoo!