Sonnenschein Nath & Rosenthal LLP - Taxation -- Representative Transactions

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Marc D. Teitelbaum
888.858.6429 212.768.6749

Thomas Stephens
888.858.6429 312.876.7485

Bruce Davison
888.858.6429 816.460.2514

Representation of U.S. transportation company in connection with the $700 million acquisition of a Mexican transportation company.
Representation of U.S. financial services company in connection with a $1 billion split-off.
Representation of National Bedding Company in its acquisition of Sleepmaster LLC, for cash and an interest in a joint venture fund formed by the contributions made by National Bedding and Sleepmaster.
Representation of Entertainment Properties Trust, a real estate investment trust, in connection with their $74 million public offering.
Representation of KeyBank and several other applicants for New Markets Tax Credit allocations.
Representation of The Stanley Works in its dispute with the IRS, which resulted in a notable victory; the IRS rescinded the declaration of taxability it had previously claimed in connection with The Stanley Works usage of the proceeds of its $10 million tax-exempt industrial revenue bond.
Representation of a public company in connection with a complex tax-sharing dispute that resulted in an arbitration proceeding.
Representation of various U.S. multinationals in connection with its international restructuring designed to lower its overall effective tax rate.
Representation of a non-U.S. telecommunications company in connection with the issuance of over $1.6 billion of securities including two registered equity offerings and three tranches aggregating $900 million in principal amount of debt issued under a Rule 144A/Regulation S medium term note program.
Representation of various non-U.S. corporations in connection with the structuring of their U.S. marketing operations, including those of a foreign garment producer, a foreign software developer, and a foreign paper manufacturer seeking to sell their products in the U.S. without being subject to U.S. tax.
Representation of financial institutions in connection with analyzing and structuring over $1 billion of tax advantaged cross-border "double-dip" financings and deductible principal and interest loans, and tax advice in connection with analyzing and structuring the ‘new’ generation of cross-border "multiple-dip" financings.
Representation of U.S. corporations in connection with their consideration of expatriating from the U.S. and advice in connection with completing one of such transactions.
Representation of a foreign insurance company in connection with structuring annuity products.
Representation of a Bermuda insurance company in connection with its private placement of stock to U.S. investors.
Representation of a foreign trust company in connection with the new U.S. information reporting and documentation rules with respect to withholding and backup withholding taxes.
Representation of foreign-based hedge fund in connection with various U.S. tax issues, including deferred compensation arrangements.
Representation of a number of U.S. public companies, primarily in the retail industry, in connection with issues concerning U.S. taxation of their foreign operations, including Subpart F issues and Section 482 issues, arising out of restructuring their foreign operations, e.g., transfer of operations to lower-taxed foreign jurisdictions, closing of unprofitable foreign subsidiaries, acquisition of other foreign entities, and various foreign joint ventures.
Representation of a U.S. technology company in connection with various joint ventures with different foreign participants for the transactions in Mexico, South Africa and Japan.
Representation of a U.S. real estate investor in connection with structuring real estate investments in Latin America.
Representation of a U.S. industrial manufacturer in connection with structuring its joint ventures in Brazil and Mexico.
Representation of various U.S. manufacturing corporations and U.S. corporations engaged in the licensing/franchising businesses in connection with withholding tax issues that arise in international trade.
Representation of various U.S. and non-U.S. corporations in connection with their e-commerce operations, such as the formation of separate U.S. companies structured to avoid or reduce U.S. state sales and income tax on e-commerce sales and the formation of foreign corporations to operate e-commerce businesses structured to defer U.S. taxation on e-commerce sales.
Representation of a U.S. public energy company in connection with a Colombian privatization of energy distribution and generation facilities.
Representation of a U.K. staffing services company and its U.S. subsidiaries in their acquisition of two U.S. staffing service businesses.
Representation of significant leveraged buyout companies in connection with tax issues arising in numerous leveraged buyouts.
Representation of large community foundation in connection with community foundation and unrelated business income tax issues.
Representation of a U.S. public electric utility company in connection with its proposed disaggregation plans.
Representation of a U.S. public toy company in connection with its plans to form a "dot-com" subsidiary to sell its toys directly to the public.
Representation of one of the largest private equity funds in connection with various tax issues, including tax issues related to qualified small business stock.
Representation of a regulated investment companies in connection with their tax-free acquisitions of the assets of other regulated investment companies.
Representation of creditor committees of airlines and automotive supplier companies in connection with Chapter 11 reorganizations, including a reorganization that has a simultaneous U.K. proceeding.
Representation of an automobile finance company in connection with a Chapter 11 reorganization.
Representation of a hotel development partnership in connection with a Chapter 11 reorganization.