Tax

Winston & Strawn’s transactional practice has substantial experience in structuring taxable and tax-free corporate restructurings, acquisitions and divestitures, as well as partnership and joint venture arrangements for both U.S. and foreign businesses. In addition, our tax attorneys are active in private equity and REIT transactions and often advise clients on the tax consequences related to corporate debt restructuring and other workouts.

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Winston & Strawn’s tax attorneys provide a broad range of tax planning services for the businesses and transactions of our large domestic and foreign-based clients. These clients represent all major sectors of the global economy. Our work in this area includes the development and utilization of tax-advantaged financings and derivative transactions, structuring foreign investment in U.S. real estate, corporate acquisitions, dispositions, joint ventures, and reorganizations; Subpart F issues; international joint ventures and reorganizations; and REITs. We also assist many U.S.-based multinationals in connection with foreign tax credit planning, including the reduction in the effective rate of foreign tax of the foreign members of the group and the utilization of hybrid structures.

Winston & Strawn now has one of the country’s leading financial tax practices. We represent major banks from Australia, Canada, France, Germany, Israel, Japan, the United Kingdom, and many other countries in connection with their operations in the United States. We represent significant domestic participants in the financial services industry, including hedge funds and private equity firms. Our team has represented financial firms at all stages of the IRS audit process, including appeals proceedings before the IRS seeking to modify or reverse audit determinations. We have obtained a number of favorable settlements and, in one case, an outright reversal of the IRS’s position, enabling our clients to avoid substantial tax assessments without litigation.

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Our Tax Controversy lawyers advise and represent clients in every aspect of tax investigations and the tax enforcement process. This includes both civil and criminal investigations, from IRS to multi-jurisdictional examinations, alternative dispute resolution including IRS Appeals and Competent Authority, and trial court and appellate litigation in every federal court hearing a tax matter. Our team provides technical expertise and a strategic approach to resolving difficult and sensitive tax matters at the earliest stage possible. Our team has decades of experience successfully resolving domestic and international tax issues for clients and includes former government trial counsel, former government prosecutors, and technical specialists with prior Big Four experience.

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