Our tax practice advises Fortune 50 companies, private investment funds, tax‑exempt organizations and other clients on complex U.S. federal income tax matters arising from high‑value domestic and cross‑border transactions. With lawyers across the U.S. and Europe and deep industry experience in financial services, energy, technology, pharmaceutical, industrials and others, we provide clients creative and cost‑effective solutions for their global transactions and strong support when tax controversy and disputes arise. 

A defining strength of our Tax practice is our close connection to government. Former senior government officials are part of our team. Their perspective informs our ability to deliver innovative, policy‑aware and commercially focused tax solutions. 

Our lawyers are deeply experienced in corporate, partnership, international and financial instrument taxation with a long‑standing global reputation for structuring and negotiating domestic and cross-border transactions.

Complex Transactions

We advise across the full range of tax issues involved in planning and executing complex transactions, including: 

• Mergers and acquisitions 
• Initial public offerings and SPAC transactions 
• Dispositions and joint ventures 
• Financings, including Islamic finance, tax equity, and tax‑credit monetization, including for utility‑scale renewable energy and advanced technology projects 
• Restructurings 
• Investment fund formations 

We also work closely with clients to address the tax aspects of employee benefits and executive compensation in connection with transactions and post‑transaction integration. Collaborating with our corporate governance, finance, fund and real estate colleagues, we ensure that all legal services necessary to close a transaction or resolve a tax issue are seamlessly integrated.

Tax Controversy and Dispute Resolution

When tax controversies arise, our team helps clients resolve them as favorably as possible through: 

• Examinations and administrative appeals 
• Litigation in U.S. Tax Court, the Court of Federal Claims, federal district courts, federal appellate courts and the United States Supreme Court 
• Alternative dispute resolution

We combine substantive tax knowledge with the firm’s litigation experience to manage privilege and discovery issues and handle appeals efficiently and strategically.

Tax‑Exempt Organizations

We also advise nonprofit and tax‑exempt organizations, including private foundations on U.S. federal tax law in particular, with respect to:  

• Qualification for exemption under section 501 
• Private foundation rules 
• Unrelated business taxable income 
• Lobbying and political activities 
• Intermediate sanctions 
• IRS audits and exemption revocations  

Our team assists new nonprofits in formation and obtaining exempt status and advises existing organizations on aspects of U.S. federal tax governance and operations. In addition to tax advice, we also counsel directors and managers on fiduciary duties, governance, endowment management and gift policies, drawing on firmwide corporate resources to prepare and revise governing documents and related agreements.