Transactional and Advisory
Davis Polk’s Tax Department is at the helm of innovation, working closely with clients on sophisticated corporate transactions. Our lawyers have far-reaching experience across the entire tax spectrum and a thorough understanding of evolving trends within the marketplace. Their highly collaborative network maximizes coordination and efficiency for our clients and their U.S., international and cross-border tax matters.
Our tax lawyers are at the forefront of delivering sophisticated legal advice regarding tax reform, including analyzing the latest developments from the IRS and Treasury.
Mergers and Acquisitions. Our tax lawyers structure and negotiate many of the most complicated U.S. and international business combinations.
Capital Markets. We advise clients on initial public offerings (including UpC IPOs) and debt financings, as well as hedging and other over-the-counter transactions, including equity monetization strategies, taxefficient share repurchase programs and cross-border hybrid transactions.
Spinoffs and RMTs. We pioneered numerous techniques for spinoffs commonly used today and have advised on many of the most high-profile deals to date.
Private Equity. We advise on tax considerations associated with fund formation, structuring of investments, financing for portfolio companies, management compensation programs, recapitalization transactions, disposing of investments through private or public sales and negotiating workouts.
Group Planning. We partner with our clients in group structuring and planning matters, including as to the application of the consolidated return regulations, so called “Granite Trust” planning, cross-border repatriation strategies, tax inversion transactions, planning for the efficient ownership of intellectual property and the potential impact of various tax reform proposals.
Banking and Finance. We are among the world’s most experienced groups in advising borrowers, sponsors, banks and other lenders on tax-related issues associated with LBOs and other leveraged financings, investment-grade financings and structured financings.
Insolvency and Restructuring. Our tax lawyers advise on the tax aspects of major bankruptcy reorganizations, workouts and other restructurings of troubled companies, with particular emphasis on preserving the debtor's net operating losses and other tax attributes, minimizing taxable debt forgiveness income and achieving the optimum tax treatment for the debtor's creditors and shareholders.
Real Estate. We regularly advise corporate, fund and private clients with respect to real estate transactions. We have represented Morgan Stanley, with respect to Prime Property Fund, and other clients with respect to the formation and operation of private and public REITs, as well as underwriters with respect to numerous REIT capital markets transactions.
Controversy. We represent clients in a wide range of industries in connection with internal risk assessments and investigations, settlements involving billions of dollars and litigation at the federal and state levels.