What I like about ET is it allows me to connect with slower less agile minds. And that's what helps keep me in touch with the other world that I know is out there. That's essential.
Here is a link to Trump's outside tax law firm. He has used the same firm since 2005.
Yeah, you are right. They don't seem competent at all. I mean recently they served as lead counsel for Amazon winning against the US Tax Court. Obviously they suck if Amazon would hire them. Isn't it easy to beat the US Tax Court? Doesn't that happen regularly by tons of attorneys? That is easy right?
I mean clearly they suck.
Link and some info below:
https://www.morganlewis.com/services/tax
Tax Controversy
Our tax controversy team is rated by
Chambers USA in the top tier, and delivers strategic, practical advice to clients involved in disputes with the IRS and state taxing authorities. Drawing upon a core group of high-level government alumni, strong Washington, DC connections, a high profile in the tax bar, and a reputation for integrity with US federal and state authorities, we energetically and effectively represent clients in these critical matters.
We represent some of the largest corporate taxpayers in the United States in cutting-edge, large-dollar domestic and cross-border tax issues and related enforcement efforts. We work seamlessly across offices, collaborating to identify the most relevant expertise to help our clients, and maintaining up-to-the-minute knowledge of developments affecting our clients.
We realistically evaluate litigation hazards and seek to achieve resolutions at the earliest possible stage. Our tax litigators guide clients through the following aspects of the controversy process:
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Up-front risk assessments and documentation in the planning process for proposed transactions
- Representation in the IRS Office of Examinations and the IRS Office of Appeals
- Representation in the mutual agreement process (MAP) to resolve cross-border adjustments
- Litigation in the US Tax Court, the US Court of Federal Claims, and multiple federal district courts
- Significant state tax disputes, with a particular focus in Massachusetts, New York, and California
We have experience and substantial strength in handling high-profile IRS enforcement issues, with an emphasis on complex structures and partnerships—inbound and outbound international tax issues generally, and cross-border transfer pricing issues in particular.
Transfer pricing is currently the leading tax enforcement issue in the United States and around the world. Our transfer pricing lawyers cover a range of important industries in both disputes and administrative resolutions through audits, the advance pricing agreement (APA) process, and the MAP. Many of the high-stakes disputes focus on the identification, movement, and valuation of intangible property of all kinds, from contracts to technology. Over the last several years, our team has been a leader in some of the most complex, contentious, and novel transfer pricing matters brought in IRS Advance Pricing and Mutual Agreement (APMA) Program proceedings.
Transactional Tax Planning and Tax Structuring
People
Our tax lawyers advise clients on transactional tax planning matters on a global basis. US domestic and international mergers and acquisitions, divestitures, reorganizations, spin-offs, joint ventures, and strategic alliances, as well as equity and debt securities offerings, are among the areas in which we offer tax counseling.
In addition to the lawyers in our domestic offices, Morgan Lewis tax lawyers work from our offices in London, Frankfurt, and Beijing. These international tax lawyers help clients structure and implement cross-border, as well as German, UK, and Chinese, mergers and acquisitions; European and global tax minimization strategies; and outbound investments from the United States into Europe and other jurisdictions.
Our transactional tax work includes:
Energy
In support of our energy practice, our tax lawyers participate in tax planning for all types of domestic and international oil and gas transactions, including master limited partnerships (MLPs), renewable energy project finance and tax equity matters, and large-scale utility transactions.
Private Equity Funds & Institutional Investors
We counsel private equity funds on tax structuring. This includes transactional tax support for fund formations, as well as portfolio company acquisitions, operations, and dispositions. Fund representations complement our robust and well-known institutional investor tax services.
Mutual Funds, REITs & Broker-Dealers
Our team advises clients on all tax-related aspects associated with the creation and operation of private and pooled investment vehicles, including mutual funds, hedge funds, real estate investment trusts (REITs), and other investment-related vehicles. We also assist our financial service clients in addressing information reporting and related matters.
International Tax Planning
Our group provides clients with international tax planning and tax optimization strategies. We counsel multinational taxpayers on tax jurisdictional issues, treaty application, antiavoidance rules, US antideferral regimes, tax rulings and holidays, repatriation planning, and withholding matters.
Life Sciences & Healthcare
Clients in the life sciences and healthcare sectors turn to us for tax planning related to mergers and acquisitions, joint ventures, and intellectual property transactions. Our clients include pharmaceutical and biotechnology companies, medical practices, health insurers, and managed care organizations.
Capital Markets
We advise clients on tax issues related to securities offerings, including the preparation of tax opinions required by the US Securities and Exchange Commission (SEC). We also counsel specialized entities, such as REITs and MLPs, on tax structuring, disclosure, and securities matters.
Public & Private Company Mergers & Acquisitions
We offer transactional tax planning, and work with public and private company clients on US domestic and international mergers and acquisitions, reorganizations, spin-offs, joint ventures and strategic alliances, and equity and debt securities offerings.
Postacquisition Integration
We advise clients on international and domestic restructurings following acquisitions, including optimal cross-border structures and consolidated return issues.
International Tax
Our European and international tax and corporate structuring team includes tax lawyers located outside of the United States, resident in Frankfurt and London. In addition to being licensed to practice tax law under the laws of France, Germany, and the United Kingdom, we have a deep knowledge of the structures and tax laws in other European jurisdictions.
Lawyers in our US offices extensively support our international tax team, which draws on the resources of the entire firm to encompass not only all aspects of tax law but also the many additional considerations in any structuring or transactional assignment.
Clients turn to us to structure international corporate groups from a tax perspective and implement the corporate structure they adopt. We can assist with establishing, liquidating, or dissolving subsidiaries and branches; drafting intercompany agreements; and planning and negotiating mergers, acquisitions, and reorganizations. We frequently take on EU tax law assignments for both US and European companies—providing advice on corporate income tax, value-added tax (VAT) issues, excise duties, and capital duties.
Our international tax group provides complex international tax planning advice and representation in:
- Cross-border and French, German, and UK mergers and acquisitions
- Pan-European and global tax minimization strategies
- Structuring outbound investment from the United States into Europe and other non-US jurisdictions
- Structuring foreign investments—such as new businesses, real estate investments, and portfolio investments—in Europe and the Middle East into US investments
- Structuring tax and operationally effective legal structures for multinational groups
- Counseling high-net-worth individuals and multinational families on the tax-effective use of offshore trusts and corporate structures
Transfer Pricing
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Our transfer pricing team has represented US and foreign-based multinational enterprises in some of the largest, most complex, and important transfer pricing disputes in recent history, including serving as lead counsel to Amazon.com in its significant win in the US Tax Court involving a cost-sharing buy-in and related issues—one of the largest transfer pricing cases ever litigated and the first involving e-commerce.
Our team has worked with every significant transfer pricing expert in the United States as well as experts in many other fields, including technology, intellectual property licensing, marketing, macro and microeconomics, accounting, and computer science.
We represent clients from a wide spectrum of industries—including high technology, e-commerce, pharmaceuticals, medical devices, energy, financial services, and consumer products—in all aspects of the transfer pricing planning and controversy processes. Our work spans matters ranging from business restructurings and a wide array of planning issues regarding the identification and valuation of intangible property and services, to audits, Internal Revenue Service and international alternative dispute resolution programs, administrative appeals, advance pricing agreements, the Competent Authority process and other transfer pricing issues under treaties, trial court litigation in the US Tax Court and refund forums, and judicial appeals.
Our lawyers are authors of Bloomberg BNA’s
Tax Management Portfolio on Transfer Pricing Litigation and they teach a transfer pricing course they developed at the Georgetown University Law Center.
