Practice/Industry Group Overview
Sutherland delivers creative, informed solutions across the spectrum of federal tax matters.
Businesses in the United States face some of the highest tax rates in the world. It’s critical that companies choose an adviser capable of delivering creative, effective tax solutions that support their long-term business objectives. With more than 70 lawyers focused on federal tax matters, Sutherland advises businesses on business formation and corporate transactions, capital formation and financing, as well as business and treasury operations. We help structure partnerships, limited liability companies and other joint venture arrangements. Our Federal Tax team handles federal tax issues in the full complement of transactional corporate tax matters, including mergers and acquisitions, dispositions, spin-offs and internal restructurings. We advise clients on tax issues relating to domestic and foreign public and private debt offerings, synthetic and hybrid instruments, swaps and derivatives, and hedging transactions. We also provide experienced counsel on tax accounting, FIN 48 reporting, worker classification issues, consolidated returns and information reporting.
Our attorneys work with all branches of government, and several tax team members have held positions at the IRS. Sutherland lawyers handle regulatory and administrative matters at the principal federal agencies, including before the IRS and the Departments of the Treasury and Justice, and support tax policy initiatives in both the executive and legislative branches.
Sutherland offers one of the nation’s leading federal tax controversy practices. We support our clients in the IRS examination and appeals processes and, if needed, in litigation. We litigate tax matters before the U.S. Tax Court, U.S. District Courts, the Court of Federal Claims, the U.S. Courts of Appeals, and the U.S. Supreme Court. Our extensive controversy experience enables us to anticipate and prepare in advance for IRS positions. In addition, we serve the needs of taxpayers in highly specific areas of federal tax law, including insurance and other financial services, exempt organizations, employee benefits and executive compensation, and estate planning.
Business perspective. Our tax analysis starts with and is driven by clients’ business objectives.
Strong partnerships. Our attorneys know the importance of understanding business, and can identify which tax considerations matter most and which tax solutions are viable.
In-depth tax knowledge. With more than 70 federal tax practitioners, we provide the expertise and innovation companies need to plan for and comply with increasingly complex federal tax requirements.
Strategic relationships. Our professional relationships and prior public service provide insight into the authorities' view of tax matters that facilitates communication and efficient resolution of tax issues.
Firm-wide support. Our tax practice is embedded in a large and diverse law firm. The legal experience and industry knowledge of our other practice groups is often helpful in addressing tax problems.
Nuts and Bolts
- Corporate taxation
- Partnership taxation
- Tax controversy and litigation
- Tax accounting
- Information reporting and tax compliance
- Tax planning and consulting
- Financial products
- Insurance taxation
- Employee benefits and executive compensation
- Tax-exempt organizations
- Estate planning
- Tax policy and legislation
- Real estate investment trusts
Businesses operating in the United States call on Sutherland to find federal tax solutions that align with their business and strategic objectives.
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.
Sutherland assists clients on structuring, documenting debt and equity offerings for BDCs and closed-end funds.
BDCs and other closed-end funds turn to Sutherland for help structuring and preparing offering documents related to public debt and equity offerings.