Practice Areas & Industries: Sutherland Asbill & Brennan LLP

 





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Practice/Industry Group Overview

Sutherland handles intricate federal, international, and state and local tax matters, providing custom solutions to address our clients’ tax needs.

Sutherland serves as tax counsel to many of the world’s most prominent corporations—including more than 35 of the Fortune 100—in every area of federal, international, state and local tax law. Our prominence in legal tax services dates back to the firm’s founding nearly a century ago. More than 100 tax lawyers represent taxpayers in federal, international, employee benefits, insurance, tax exempt, and state and local tax matters. By virtue of the size of our tax practice and our varied client base, we are active in every area of taxation—from planning the most complex corporate tax transactions to representing taxpayers in administrative and judicial tax controversies.

Our tax practice counsels in domestic and international tax planning, tax controversy, insurance taxation, joint ventures and partnerships, tax accounting, state and local tax, employee benefits, executive compensation and wealth management. Our tax attorneys apply a cross-disciplinary, cross-office approach to uncover new opportunities and develop creative solutions.

Our tax lawyers are recognized for their skills and acumen with appointments to national leadership positions in government and the private sector. Our firm has produced two IRS commissioners, one IRS Chief of Appeals and one IRS chief counsel. Further, our tax team includes attorneys who have held other positions at the IRS, the Treasury Department, and the Tax Division of the Justice Department.  Members of our team have also served as leaders in the American Bar Association’s Section of Taxation, the Internal Revenue Service Advisory Council, the American College of Tax Counsel, the International Fiscal Association and the Council On State Taxation.

Why Sutherland
Deep tax knowledge.
More than 100 attorneys focus their practices on federal, international, state and local tax law.

Collaborative approach. We partner with corporate in-house teams to develop effective strategies for tax planning, transactions and disputes that serve the client’s tax and business objectives.

Connections. Many of our tax attorneys, including our tax litigators, served in federal, state or local government positions. This gives our tax team an understanding of the authorities' view of tax matters that can facilitate resolution of issues.

Success. Our clients recognize the results we achieve across all areas of our broad-based tax practice.

Firmwide support. Our tax lawyers are part of a much bigger and more diverse law firm. They can draw on the talents and experience of other attorneys with a vast range of understanding and knowledge—from energy to financial services.

Nuts and Bolts
Our key experience includes:

  • Federal taxation
  • International taxation
  • State and local taxation
  • Tax controversy and litigation
  • Joint ventures and reorganizations
  • Mergers, acquisitions, dispositions and spinoffs
  • Employee benefits and executive compensation
  • Income taxes, property taxes, and sales and use taxes
  • Partnership tax
  • Audits and disputes
  • Inbound and outbound tax planning
  • Transfer pricing
  • Withholding and information reporting
  • Wealth management
  • Tax accounting

Take Action
If you have a need for deeply experienced tax counsel and pragmatic, efficient tax solutions, our tax attorneys can help.

Selected Experience
Sutherland acts as tax counsel in $25 billion spinoff.
Sutherland acts as tax counsel to Mondelez International in its approximately $25 billion spinoff of Kraft Foods Group.

Sutherland represents international insurance company in tax litigation regarding $306 million tax refund.
Sutherland represents an international insurance company in a refund suit that it filed for its 1997 tax year, seeking the return of approximately $306 million in tax, penalties and interest. The case involves a number of issues, including whether the company is entitled to certain foreign tax credits that it claimed in various cross-border financing transactions.

W. L. Gore retains Sutherland in complex state tax litigation.
Sutherland is representing W. L. Gore in landmark litigation regarding the state taxation of holding companies.


 
 
Articles Authored by Lawyers at this office:

Impact of International Tax Reform Proposals on U.S. Insurance Companies
Dennis L. Allen,Thomas A. Gick,Jerome B. Libin,Jeffrey H. Mace,Michael R. Miles, November 27, 2013
On November 19, retiring Senate Finance Committee Chairman Max Baucus (D-Mont.) released a “Discussion Draft” setting forth his international tax reform proposals. Of note, the Discussion Draft includes several proposals that target the international operations of U.S. insurance...

Senate Finance Committee Chairman Baucus Releases International Business Tax Reform Discussion Draft
, November 27, 2013
On November 19, 2013, Senate Finance Committee Chairman Max Baucus (D-Mont.) released a “Discussion Draft” of international tax reform proposals. The Discussion Draft proposes significant changes to the taxation of foreign income, including substantially expanding the definition of...

BATSA Up: Congress Once Again Considers Nexus Legislation
Andrew D. Appleby,Zachary T. Atkins,Madison J. Barnett,Marlys A. Bergstrom,Jonathan A. Feldman, April 27, 2011
Would Thomas Jefferson approve of Congress imposing its will on state efforts to collect income tax from out-of-state companies? That was the question posed by Rep. Steve Cohen (D-TN) to two sponsors of the Business Activity Tax Simplification Act of 2011 (BATSA) (H.R. 1439) who both happen to be...

ACLU Sues North Carolina Over Its Sales/Use Tax Audit Practice
Michele Borens,Jeffrey A. Friedman,Stephen P. Kranz,Marc A. Simonetti,Eric S. Tresh, July 15, 2010
The aggressiveness of some states to assert tax jurisdiction over out-of-state retailers (or to enforce tax against their customers) took another turn last week. On June 23, 2010, the American Civil Liberties Union (ACLU) filed a complaint in U.S. Federal District Court against Kenneth Lay in his...