Tax

Davis Polk has long been a leader in domestic, cross-border and international tax law. Our tax lawyers continue to remain at the helm of innovation, working closely with clients on complex transactions and corporate structures, as well as first-of-their-kind derivatives and other financial products. 

In financial products, capital markets, mergers and acquisitions, investment funds and bankruptcy, we contribute significantly to the market-leading practices of the firm and are at the center of the most important transactions, developments and controversies in tax law. 

Our tax lawyers are brought in to advise on many landmark transactions that highlight our cross-border and international tax capabilities, including: 

  • Shire’s $54.8 billion acquisition by AbbVie

  • H.J. Heinz’s $28 billion acquisition by an investment consortium comprised of Berkshire Hathaway and 3G Capital

  • CNOOC’s $15.1 billion acquisition of Nexen

  • Warner Chilcott’s all-stock $8.5 billion acquisition by Actavis

  • BB Seguridade’s $5.7 billion IPO – the largest global IPO of 2013

  • Sinopec’s $5 billion notes offering – the largest global debt offering by a mainland Chinese corporate to date

  • Banco Santander’s €4.686 billion all-stock offer to acquire all the shares of Banco Santander Brasil

  • Daiichi Sankyo’s $4 billion acquisition of Ranbaxy Laboratories by Sun Pharma

  • China Everbright Bank’s $3.4 billion IPO – the largest IPO in Hong Kong in 2013

  • Royal Mail’s $2.75 billion IPO – the largest IPO in London in 2013

Our tax controversy matters span a broad range, including issues involving partnership and international taxation, as well as questions relating to financial products, employee benefits, residency and domicile, tax accounting and debt-equity characterization. 


In the rare instances when our clients’ cases have gone to trial, our litigation strategy has been successful, most recently in our victories for National Westminster Bank and AmBase.

Recognition

  • Law360 – among the Tax Practice Groups of the Year,” 2014 >
  • Chambers Global – Tax, Corporate and Finance: USA, Band 1
  • Chambers USA:
    • Tax, Corporate and Finance: Nationwide, Band 1
    • Tax: New York, Band 1
  • Legal 500 U.S.:
    • Tax, Non-Contentious, 1st tier
    • Tax, Financial Products, 1st tier
    • Tax, International, 1st tier 

Our tax practice continues to receive recognition for many of the successful representations completed on behalf of our clients, including: 

  • International Tax Review – Americas Capital Markets Tax Deal of the Year (Fhipo's IPO), 2015 
  • International Tax Review – Americas Private Equity Tax Deal of the Year (Acquisition of GE Capital real estate assets by funds managed by Blackstone), 2015 
  • International Tax Review  Americas Banking Tax Deal of the Year (Sallie Mae’s Strategic Separation of Navient), 2014
  • International Tax Review – U.S. Tax Court/Federal Claims Court Firm of the Year (PepsiCo), 2013 

  • International Tax Review – Americas Capital Markets Tax Deal of the Year (High Yield issuance by Linea Amarilla – Estudio Echecopar), 2013 

  • International Tax Review – Americas Media & Entertainment Tax Deal of the Year (Sale to Comcast of GE’s remaining 49% stake in NBC Universal), 2013