Cliff Muller, a member of Sutherland's Tax Practice Group, practices exclusively in the area of federal tax law and concentrates primarily on transactions with international tax implications. Cliff has extensive experience analyzing international issues and structuring international transactions, including acquisitions, dispositions, reorganizations, transfer pricing, repatriation techniques, Subpart F planning, currency transactions, principal and finance company arrangements, and financial instruments with cross-border implications. Cliff works regularly with the Internal Revenue Service (IRS) and U.S. Department of the Treasury regarding regulation projects, formal rulings and informal advice, and with Congressional Committee staffs regarding the technical operation of statutory and bill language. Cliff was an associate professor of law at the George Washington University National Law Center and taught a course titled, "Special Problems in Corporate Taxation," which addressed the issues involved with taxable and nontaxable mergers, tax-free spin-offs, intragroup sales, consolidated returns and other corporate tax issues. Cliff has been involved in some of the most significant acquisition and disposition transactions in recent years, as described below. Representative Experience Cliff's extensive representative experience includes: · Representing Kraft as tax counsel in its acquisition of Cadbury, valued at approximately $19 billion (2010). · Representing Altria as tax counsel in its acquisition of UST, valued at approximately $11.7 billion (2009). · Representing 3M as tax counsel in its approximately $1.2 billion acquisition of Aearo (2008). · Representing Altria as tax counsel in Altria's spin-off of Philip Morris International Inc., one of the largest spin-offs to date, valued at approximately $113 billion (2008). · Representing Kraft as tax counsel in its approximately $2.6 billion tax-free split-off of its Post cereals business and the merger of the Post cereals business into a subsidiary of Ralcorp Holdings (2008). · Representing Philip Morris International as tax counsel in its approximately $2 billion acquisition of Rothmans Canada (2008). · Representing Philip Morris USA as tax counsel in its approximately $2.9 billion acquisition of John Middleton, Inc. (2007). · Representing Altria as tax counsel in its approximately $50 billion spin-off of Kraft (2007). · Representing Kraft as tax counsel in its purchase of Group Danone's global biscuit business for approximately $7.6 billion (2007). · Representing Philip Morris International as tax counsel in its acquisition of an increased stake in its Mexican tobacco business for approximately $1.1 billion (2007). · Representing Philip Morris International as tax counsel in its approximately $5 billion acquisition of PT HM Sampoerna Tbk, an Indonesian cigarette company (2005). · Representing Altria as tax counsel in its approximately $5.6 billion sale of Miller Brewing Company to South African Breweries PLC (2002). · Representing Altria and Kraft in the acquisition of Nabisco for approximately $15 billion in 2000 and the subsequent offering of more than $8 billion of Kraft stock in 2001 in the second-largest IPO ever undertaken. Professional Honors and Awards · Recognized by Chambers Global: World's Leading Lawyers in the area of international tax (2011) · Recognized by The Legal 500 United States in the area of tax: international (2011) · Named to The Best Lawyers in America in the area of tax law (2006-2012) · Recognized by the Washington Business Journal as the Top Washington Lawyer in the area of tax (2009) · Selected to be included in the Legal Media Group Guide to the World's Leading Tax Advisers · Recognized by International Tax Review's World Tax 2009-the comprehensive guide to the world's leading tax firms Professional and Community Involvement · Member, Committee on Financial Transactions, American Bar Association · Former Committee Chairman, Subcommittee on International Financial Transactions, American Bar Association Recent Speaking Engagements · Speaker, "Repatriation: Cash Planning and APB 23: Implications for Provisions and Disclosures," TEI Financial Reporting Seminar (September 24, 2009) · Speaker, "The Integration Process," Tax Executives Institute (TEI) Merge Right, Yield Nothing: Practical Solutions to Challenging International M&A Issues (June 20, 2008) News International Recognition: Sutherland Featured in 2012 Edition of Chambers Global
December 5, 2011 Sutherland Makes Mark in The Legal 500 for 2011
December 1, 2011 Washington Business Journal's Top Washington Lawyers: Tax Winner
September 18, 2009 Reprinted with permission Washington Business Journal The Dealmakers
April 10 -16, 2009 Reprinted with permission Atlanta Business Chronicle Sutherland Represents Altria Group, Inc. in its $100 Billion Spin-off of Philip Morris International Inc.
March 31, 2008 Legal Alerts Legal Alert: American Jobs Creation Act of 2004
October 25, 2004 Events TEI Financial Reporting Seminar
September 24, 2009 Tax Executives Institute (TEI) Merge Right, Yield Nothing: Practical Solutions to Challenging International M&A Issues
June 20, 2008 |