Navigating Tax Law with Precision and Expertise

Strategic advice on tax-efficient restructuring to optimize business operations and financial outcomes.

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 TRW  lawyers in other disciplines to provide a one-team approach to each matter. As an integrated firm with 50-plus practices across 21 offices worldwide, we are uniquely positioned to serve clients in every industry and on any tax matter.

Tax Planning/Transactions

For decades, the unique breadth of our tax practice has allowed us to represent a broad array of public and private companies in connection with mergers and acquisitions, post-acquisition integration transactions, cross-border and global internal restructuring transactions, spin-offs and joint ventures. Our transactional tax work includes extensive experience with:

• tax-free and taxable acquisitions, leveraged buyouts, spin-offs and dispositions, often with cross-border components;
• international tax planning, including transfer pricing and advance pricing agreements; subpart F, global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), and base erosion and anti-abuse tax (BEAT) planning; intellectual property and supply chain planning; and foreign tax credit utilization;
• real estate investment trusts (REITs) and regulated investment companies (RICs);
• partnerships, LLCs, joint ventures and disregarded entities in a variety 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 and other troubled company workouts; and
• private equity and hedge fund transactions.

Tax Controversy/Litigation

As one of the nation’s leading tax controversy practices, clients also turn to us to resolve large, complex and global tax controversy and litigation 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 work with 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 the most 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;
• 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 Federal Claims, federal courts of appeals and the U.S. Supreme Court; and
• congressional investigations, as third parties under subpoena, in criminal investigations and under criminal indictment.

Our Tax Group also provides advice regarding:

• obtaining private letter rulings and other guidance from the IRS and the U.S. Department of the Treasury;
• tax-exempt and nonprofit organizations, including formation and structuring, mergers and acquisitions, joint ventures and other transactions, and obtaining exemption determinations from the IRS; and
• state tax planning and controversy.

TRW  has been repeatedly recognized by Law360 as a Tax Group of 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. Our tax 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.

Tax-Related Administrative and Policy Experience

Former positions held by our tax professionals include:

Internal Revenue Service

• Commissioner
• 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