Tax

The Tax Practice Group provides large multinational corporations, publicly traded and private companies, sovereign wealth funds, investment funds, partnerships, joint ventures and startups with state-of-the-art tax advice.

The Tax Practice Group’s transactional practice provides tax advice to clients in connection with a broad range of business transactions and investments, including:

• Taxable and tax-free mergers
• Acquisitions
• Reorganizations and dispositions (including spin-offs and split-offs)
• Insolvency restructurings
• Business combinations
• Capital markets offerings
• Investment fund formation
• Infrastructure investments
• Real estate acquisition and disposition
• Specialized investment vehicles, including master limited partnerships and real estate investment trusts

Within the United States, the U.S. members of the Tax Practice Group have developed significant knowledge and capabilities in all aspects of U.S. income taxation.  Our lawyers work with clients on day-to-day planning, allowing us to detect tax concerns and opportunities early on and to devise and implement innovative, practical solutions for best possible results.  We advise clients on transactional, international and tax litigation and administrative matters.  Our global reach allows the Tax Practice Group to advise U.S. companies on European and Asian tax matters, covering both direct and indirect taxes.

Within Gibson, Dunn & Crutcher’s non-U.S. offices, our tax lawyers are qualified to practice under the laws of the United States, England and Wales, France and Germany.  The Tax Practice Group’s international reach permits a full range of tax services to corporations, partnerships, financial institutions, investment funds, sovereign wealth funds and other non-U.S. entities.  The Tax Practice Group also advises on structuring and negotiating cross-border acquisitions, dispositions and other business combinations as well as inbound and outbound investments.  We also advise on the taxation of international employment engagements, including employee incentive arrangements.

The Tax Practice Group represents clients in litigation and administrative inquiries, audits, appeals proceedings and tax litigation relating to U.S. federal and state and European tax issues.  In addition, we provide Gibson Dunn’s outstanding team of internationally known litigators with advice on the taxation of various litigation-related issues, including the tax implications of settlements and verdicts, as well as the corresponding reporting obligations.

Experience

Many of our transactions are private and cannot be disclosed.  Recent examples of public transactions in connection with which the Tax Practice Group assisted clients with innovative tax strategies include the following:

• AECOM, in its $4 billion acquisition of URS Corporation.
• Vivendi SA in its tax-free sale of shares in Activision Blizzard Inc.
• A consortium of Chinese companies in its acquisition of OmniVision Technologies Inc. for nearly $2 billion.
• Tri Pointe Homes in its $2.7 billion acquisition of Weyerhauser’s home-building division by means of a “reverse Morris Trust” transaction.
• Robert Bosch GmbH in its €3 billion acquisition of a 50% stake in Bosch BSH GmbH from Siemens AG.
• Hewlett-Packard Company in its $2.7 billion acquisition of Aruba Networks, a provider of enterprise wireless LAN and edge access networking equipment.
• Lion Gables Apartment Fund L.P. in its $3.2 billion sale of Gables Residential Services, a privately held real estate investment trust (REIT) that owns, develops, and manages apartment complexes, to a group of investors led by Clarion Partners.
• Coty in connection with its acquisition of the international cosmetics group Bourjois from French haute couture and cosmetics group Chanel for a consideration of approximately 15.43 million shares of Coty’s Class A common stock.
• Doremi Labs, the leading provider of digital cinema video playback solutions, in connection with Dolby Laboratories Inc.’s acquisition of Doremi Labs and French distributor Highlands Technologies SAS.

For additional information, please visit our global Tax Controversy and Litigation practice page.