Tax

The tax practice group of Chadbourne is considered one of the most well-known and well-regarded tax practice groups in the United States.

Our tax lawyers are leading practitioners in every aspect of taxation and have held senior positions in the U.S. Treasury, bar associations and the academic community. The group includes a former Deputy International Tax Counsel for the U.S. Treasury, a former head of New York University’s Tax LL.M. program, a recent Chairman of the New York State Bar Association’s Tax Section, a former tax counsel for Senator Daniel Patrick Moynihan, present and former faculty members at the New York University and Yale Law Schools and two former attorney-advisors for the U.S. Tax Court.

U.S. and International Transactions

Chadbourne tax lawyers work closely with our clients (and with lawyers throughout the Firm in corporate, energy, project finance, private equity, financial products, bankruptcy, trusts and estates and real estate) to ensure the best possible solution to any tax problem. Our tax lawyers have planned, structured, negotiated and implemented numerous high-profile, tax-sensitive U.S. and cross-border M&A transactions and significant international reorganizations. We represent numerous private equity funds and hedge funds and are actively involved in developing new financial products and state-of-the-art international debt and equity financing structures. Chadbourne tax lawyers have created and pioneered innovative, tax-enhanced private equity buyout structures. The tax group’s experience and creativity extends to a broad array of other areas, including, asset based financing and securitizations, global private business and family estate planning, international investment funds, securities offerings, project financings, real estate transactions, solar energy and alternative energy structures and transactions.

Private Businesses and High Net Worth Individuals

Chadbourne's leading private business and high net worth individual practice draws on our U.S. and international expertise to achieve both tax and non-tax objectives for our U.S. and international clients. Our tax department works closely with our trusts and estates department in every phase of this practice, which is particularly important in this world of high U.S. and foreign income and estate tax rates. Our tax department also structures and regularly advises private foundations, public charities and other tax-exempt entities (both small and large).

Tax Controversies and IRS Rulings; Tax Legislative and Regulatory Practice Areas

Chadbourne tax lawyers have been lead lawyers in many major tax controversy matters. Recent cases have included representation of a multimedia international conglomerate (in which the IRS proposed hundreds of adjustments and deficiencies of hundreds of millions of dollars and in which the taxpayer ultimately received a refund); representation of the New York Clearing House banks (in the settlement of a controversy with New York City concerning offshore bank income); representation of an insurance company before the Court of Federal Claims (in which the company received one of the largest refunds ever paid by the IRS); representation of numerous public and private companies before the IRS in audit and appeals (in which resolutions with the IRS have been termed by our clients as “spectacular”) and in competent authority proceedings under tax treaties; representation of numerous foreign-owned U.S. companies (involving intercompany transfer pricing and other Section 482 issues); representation of a trucking company before the District Court and Court of Appeals (involving an important tax issue for the trucking industry); and even representation of a New York University professor before the U.S. Tax Court and Court of Appeals (involving the taxability of scholarships).

The tax group has obtained from the IRS important, precedent-setting private letter rulings on behalf of our clients. Our reputation has also been instrumental in our efforts to make changes to Treasury regulations and to have a major impact on legislative proposals, both in terms of broad tax policy and in the most focused provisions.

Representative Experience