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Practices / Tax

Tax

Federal, state, and international tax planning, controversies, and transfer pricing.

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Our tax practice handles transactional tax structuring, transfer pricing, advance pricing agreements, and tax controversy. We have resolved matters with the IRS Large Business & International division, HMRC, and the Inland Revenue Authority of Singapore.

We do not separate tax planning from tax controversy — the lawyers who structure the transaction are the ones who defend it.

Practice lead

Roberto Ferreira

Partner · New York

Roberto Ferreira is a partner in the tax and regulatory practices. He has structured cross-border transactions involving more than 30 jurisdictions, and has resolved transfer pricing matters with the IRS, HMRC, and the Brazilian Receita Federal. He previously served as attorney-advisor in the Treasury Department's Office of Tax Legislative Counsel.

Representative matters (2)

  • Technology 2024

    Transfer pricing matter resolved with IRS LB&I

    Resolved a multi-year transfer pricing examination by the IRS Large Business & International division for a multinational technology company.

    No adjustments; advance pricing agreement signed covering the next five years.

    N/A New York
  • Industrials 2023

    Cross-border restructuring with tax-efficient step-up

    Structured the cross-border reorganization of an industrial group to achieve a full step-up in basis across nine jurisdictions.

    Implemented with no current tax cost; expected annual savings of $40M.

    $1.4B New York

Team (2)

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