The 150 tax lawyers around our international network have a pre-eminent transactional tax practice. They are well known in their own countries and they work regularly with each other on complex international transactions. The US tax practice focuses on capital markets and corporate tax issues, with a particular emphasis on cross-border structuring, private equity and financial products. Working closely with the tax lawyers throughout the firm, our US tax team brings a strong set of resources to bear on structured finance matters ranging from securitizations to derivatives and other complex structured products. The team also advises on major corporate transactions, such as mergers and demergers where shareholders and entities are in multiple countries, and on private equity structures to enhance returns from multinational portfolio investments.

Recent experience includes advising:

  • a consortium consisting of Apax Partners, Goldman Sachs Capital Partners and Providence Equity on the €2bn acquisition of Deutsche Telekom's remaining cable TV interests in six German federal states, including favorable tax structuring and asset basis step-up elections;
  • IM Internationalmedia, a public German media company, on structuring its planned cross-border acquisition of a US-based film production company in a tax-free share-for-share transaction;
  • two of the world's largest US-based global private equity funds on investing in and taking private German industrial companies valued at €1.4bn;
  • a non-US bank's US subsidiary on issuances of DRD-eligible preferred stock to monetize US net operating losses;
  • a UK plc on structuring a demerger to be tax-free to US shareholders;
  • a UK plc on the worldwide restructuring of its branded goods business in anticipation of demerger and UK flotation;
  • a UK bank on a structured securities loan with a Dutch bank;
  • a Canadian investment bank on US tax aspects of its derivative financial products and securities lending;
  • a European investment bank on the US tax aspects of the development of financial products for cross-border applications;
  • a leading US defense and systems integration contractor on research credit refund claims in an IRS audit, IRS appeals mediation and a pre-filing agreement;
  • a German commercial bank on establishing a $5bn multi-currency securitization conduit;
  • the Valentia consortium, comprising Providence Equity Partners, Soros Private Equity Partners, Goldman Sachs, Sir Anthony O'Reilly and the eircom ESOT, on tax advantage restructuring for repatriation of whole business securitization proceeds following Valentia's take-private acquisition of eircom in Ireland;
  • a collateralized debt obligation fund structured to originate loans without exposing non-US investors to US tax; and
  • a US monoline insurance company on a structured stand-by preferred equity facility.

More information on Freshfields' global tax practice.

For more information please contact Brian Rance, US managing partner or Christa Crane, business development manager.

Careers

Information on our US careers

Related Practices

Tax

Contacts

More contacts