Tax

Skadden’s Tax Group, comprising more than 120 attorneys in nine offices
worldwide, is experienced in virtually every type of matter that presents
significant tax issues. In addition to handling all aspects of tax law incorporate transactions, we represent clients at every level, and in mosttypes, of disputes with taxing authorities.

With extensive experience at the Department of the Treasury, IRS
and White House, as well as in congressional tax writing committees, our tax professionals are highly skilled in handling intricate tax
issues with the goal of reaching creative and value-added solutions
tailored to each client’s specific needs. Our Tax Group also closely
coordinates its efforts with Skadden lawyers in other disciplines toprovide a one-team approach to each matter. As an integrated firmwith 50-plus practices across 21 offices worldwide, we are uniquely
positioned to serve clients in every industry and on any tax matter.
For decades, the unique breadth of our transactional tax practice andour geographical reach have allowed us to represent a broad arrayof public and private companies in connection with mergers andacquisitions, post-acquisition integration transactions, cross-borderand global internal restructuring transactions, spin-offs and jointventures. Our transactional tax work includes extensive experiencewith:- tax-free and taxable acquisitions, leveraged buyouts, spin-offs anddispositions, often with cross-border components;- international tax planning, including transfer pricing and advancepricing agreements; subpart F, global intangible low-taxed income(GILTI), foreign-derived intangible income (FDII), and baseerosion and anti-abuse tax (BEAT) planning; intellectual property
and supply chain planning; and foreign tax credit utilization;- real estate investment trusts (REITs) and regulated investmentcompanies (RICs);- partnerships, LLCs, joint ventures and disregarded entities in avariety of unique contexts and in virtually every industry sector;- corporate finance and funding transactions, recapitalizations, project finance, tax equity transactions and leasing transactions;- Chapter 11 reorganization cases, nonjudicial restructurings andother troubled company workouts; and- private equity and hedge fund transactions.
As one of the nation’s leading tax controversy practices, clients also
turn to us to resolve large, complex and global tax controversy andlitigation matters. We represent corporations, partnerships, estates,individuals and government entities facing every kind of tax liability
including income tax, estate tax and excise tax. We regularly workwith our clients to resolve their disputes quickly and privately,through the administrative process. In addition, our highly regarded
tax litigators have experience representing clients in many of themost significant tax cases in the United States. Our tax controversy
work includes:- audit, administrative appeal, mediation and arbitration, deficiency
and refund litigation, and international matters involving competent authority disputes (APMA);- global settlements, fast-track appeals settlements, prefiling agreements and similar expedited resolution strategies;- tax litigation, both at trial and on appeal, in all jurisdictions —U.S. Tax Court, the federal district courts, the U.S. Court of FederalClaims, federal courts of appeals and the U.S. Supreme Court; and- congressional investigations, as third parties under subpoena, incriminal investigations and under criminal indictment.

Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates

TaxContinued

Our Tax Group also provides advice regarding:

Tax-Related Administrative and Policy Experience- obtaining private letter rulings and other guidance from the IRS
and the U.S. Department of the Treasury;

Former positions held by our tax professionals include:- tax accounting, including capitalization, cost recovery, mark-tomarket and accounting method change questions;- Commissioner- tax-exempt and nonprofit organizations, including formation andstructuring, mergers and acquisitions, joint ventures and othertransactions, and obtaining exemption determinations from theIRS; and- state tax planning and controversy.
Skadden has been repeatedly recognized by Law360 as a Tax Groupof the Year since 2015, and ranked No. 1 in Vault’s Best Law Firms
for tax every year since 2010. We also were named 2023 Tax Law
Firm of the Year in U.S. News — Best Lawyers, as well as 2024
Washington DC Tax Firm of the Year and San Francisco/Bay Area
Transfer Pricing Firm of the Year by International Tax Review. Ourtax practice and its members are ranked in Chambers USA, Chambers Global, Chambers High Net Worth, The Legal 500 and International Tax Review’s annual World Tax guide.

Internal Revenue Service- Chief counsel- Associate chief counsel, Corporate- Area counsel for financial services, Office of Chief Counsel- Commissioner of the Small Business/Self-Employed Operating
Division- Team Leader, Advance Pricing and Mutual Agreement (APMA)US Department of the Treasury- Assistant secretary for tax policy
White House- Special assistant to the president for budget and tax policy,
National Economic Council
Joint Committee on Taxation- Legislative counsel experience“Leading firm with outstanding bench strengthand renowned expertise spanning the full spectrum of domestic and international tax matters.
… Trusted to handle some of the most significant
matters in the corporate tax sphere, from large
M&A to headlining transfer pricing litigation.”— Chambers USA 2024

Skadden ranked first by deal count in spinoffs (parent company representations) closing
between 2019-23.
— Deal Point Data

2 Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates