In order to stay competitive in today’s global marketplace, companies must achieve greater efficiency in their tax planning and compliance efforts, taking into account tax requirements and their implications from the various countries in which they operate. Increased scrutiny and restrictive legislation demand greater self-evaluation and require skillful representation in tax controversies and litigation.
Business transactions of every type, whether acquisitions, dispositions or restructurings, require thoughtful tax planning. Dechert’s multidisciplinary international and domestic Tax group assists clients in addressing their tax planning needs and resolving tax controversies. We are always mindful of our clients’ business objectives, providing transaction structures that maximize tax benefits and minimize tax liability. With lawyers in the United States and Europe, we are positioned to counsel clients on effective international tax planning strategies, providing integrated, global tax advice.
Acquisitions and Divestitures
Working closely with our corporate and securities lawyers, Dechert helps clients structure, negotiate and execute taxable and tax-free transactions, including domestic and cross-border mergers and acquisitions, joint ventures, leveraged buyouts, spin-offs, divestitures and liquidations. In addition, we provide tax advice in connection with initial public offerings, secondary offerings and other securities-related transactions. Taking a proactive approach, we regularly conduct due diligence reviews to bring to light potential tax liabilities and provide risk management advice.
We provide assistance with domestic and multi-jurisdictional restructurings, bankruptcies and workouts, as well as international financings and recapitalizations, carefully taking into account their tax implications and minimizing their impact.
Dechert lawyers also provide tax advice in connection with securitizations, including REMICs, real estate finance, structured finance, as well as the formation of and investment in mutual funds, offshore investment funds, venture capital funds and high-tech businesses. We frequently counsel clients on the tax-efficient use of special purpose vehicles, such as REITs, regulated investment companies (RICs) and other investment vehicles.
We have represented financial services firms and investment management companies in transactions involving the development of novel financial instruments and routinely advise fund managers of both open- and closed-ended funds on matters such as developing tax-efficient structures for employee co-investment funds.
In the United Kingdom, we offer sophisticated advice to property finance clients and regularly advise real estate investors, developers and purchasers on corporate tax, stamp duty and value-added tax.
U.S. and European clients count on Dechert for skillful representation in all aspects of contested tax matters, including audits, investigations, administrative appeals and court proceedings.
We handle tax contests efficiently and strive to achieve favorable settlements for our clients. When settlement is not feasible, we effectively and efficiently litigate. In the United States, Dechert lawyers have litigated tax cases in the U.S. Tax Court, the Court of Federal Claims and various federal district courts and circuit courts of appeal. In the United Kingdom, we have represented clients before the High Court and Court of Appeal. Additionally, we work closely with our white collar and securities partners in connection with complex criminal tax proceedings.
Dechert’s international tax lawyers have extensive experience helping multinational clients develop and implement transfer pricing strategies that support their overall international tax plan, while complying with the often complex transfer pricing rules of different jurisdictions.
Our team helps clients develop a comprehensive transfer pricing plan that maximizes profits and reduces overall risk and we resolve any existing transfer pricing controversies.
Working collaboratively with members of our other practice groups, including our corporate, securities and shareholder litigation, securities enforcement, financial Services and investment management, finance, real estate, bankruptcy, business restructuring and reorganization and white collar defense groups, we provide seamlessly integrated legal services to close transactions and resolve the full range of tax disputes.