Hal Hicks is the global head of the international tax practice and a member of the firm's Opinion Committee.

Bio

Mr. Hicks' practice focuses on a wide range of international tax issues for multinational corporations, partnerships and other entities involving both tax planning and tax controversy. Mr. Hicks has broad-based experience, particularly in the areas of international M&A, foreign tax credit, transfer pricing and subpart F. He is a highly recognized and frequent speaker and author.

Mr. Hicks repeatedly has been recognized as a leading tax adviser in Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business, Euromoney’s Guide to the World’s Leading Tax Advisers, The Best Lawyers in America (Tax Law and Tax Litigation and Controversy), Tax Directors Handbook, The International Who’s Who of Corporate Tax Lawyers, Who’s Who Legal: Corporate Tax, Who’s Who in American Law and in the international tax section of The Legal 500, among other publications. He is a fellow of the American College of Tax Counsel. Prior to coming to Skadden, Mr. Hicks served as the international tax counsel at the Department of Treasury from 2005-2007, and as associate chief counsel (international) in the Office of Chief Counsel at the IRS from 2003-2005. He is one of only two people to hold both top international positions at Treasury and Office of Chief Counsel.

Mr. Hicks has represented clients in a wide range of transactions and other matters, including:

  • AbbVie Inc. as corporate finance, banking and tax counsel in its $55 billion combination with Shire plc;
  • Sara Lee Corporation in connection with its restructuring, spin-off and migration;
  • Valeant Pharmaceuticals International in its $3.5 billion merger with Biovail Corporation (Canada);
  • Wynn Macau, Limited and Wynn Resorts, Limited in their $1.87 billion initial public offering and listing in Hong Kong;
  • Schering-Plough Corporation with the tax aspects of its $41 billion acquisition by Merck & Co., Inc., a pharmaceutical and biotechnology company;
  • The Coca-Cola Company in connection with the multibillion-dollar acquisition and restructuring of Coca-Cola Enterprises;
  • BlackRock, Inc. in connection with its $14 billion acquisition of the asset management business of Barclays, and the post-acquisition restructuring and integration;
  • the audit committee and independent directors of Ensco, Inc. in connection with a major restructuring and migration;
  • numerous clients on substantial matters in connection with acquisitions, restructurings and IRS matters, including Liberty Mutual; Cargill, Inc.; Access Industries; General Electric; Exxon Mobil Corporation; James Hardie Industries Ltd.; MetLife, Inc.; Hewlett-Packard Company; Pfizer, Inc.; Biogen Idec, Inc.; Vodafone Group Plc; and Citigroup Inc.; and
  • numerous clients in tax planning and restructuring matters, including Hewlett-Packard, General Electric, Wynn Resorts, IBM, E. I. du Pont de Nemours and Company, The Coca-Cola Company, ExxonMobil and Liberty Mutual.

In addition, Mr. Hicks has represented clients in audits, appeals and otherwise before the Internal Revenue Service and the Department of the Treasury.

As the international tax counsel at the Department of the Treasury, Mr. Hicks was the principal legal adviser to the secretary and the assistant secretary (tax policy) on all international tax matters. He oversaw the lawyers and economists working in the international tax area, including with respect to legislation, treasury regulations and other published guidance and treaties. Mr. Hicks led the U.S. delegation at the OECD and other international tax forums. As associate chief counsel (international), he supervised more than 120 international tax professionals, including those in the Advanced Pricing Agreement Program. His group was responsible for published guidance, TAMs, private rulings, closing agreements and APAs in all areas of international tax. Mr. Hicks also served as principal legal adviser on all international tax matters to IRS National Office, Field, Exam and Appeals. Mr. Hicks received both the Treasury Honor Award and the Chief Counsel Award for his government service.

Prior to his government service, Mr. Hicks had been in private practice for many years, representing clients in planning and controversy on both outbound and inbound matters, as well as on U.S. matters.

Credentials

Education

  • LL.M. (Tax), New York University School of Law
  • J.D., University of Virginia School of Law
  • B.A., College of William and Mary

Honors

  • Professor Richard Pugh Distinguished International Tax Award, University of San Diego School of Law – Procopio International Tax Institute (2014)
  • U.S. Treasury Honor Award (2007)
  • Chief Counsel Award (2005)

Admissions

  • District of Columbia

Associations

  • Member, Advisory Board, IRS/GW Conference
  • Member, Advisory Board, International Tax Journal
  • Member, Advisory Board, University of Chicago Tax Conference
  • Fellow, American College of Tax Counsel
  • Adjunct Professor, Georgetown University Law Center

Government Service

  • International Tax Counsel, Department of Treasury (2005-2007)
  • Associate Chief Counsel (International), Internal Revenue Service (2003-2005)