Federal & International Tax
ENTERPRISE has a highly acclaimed, diversified tax practice covering every area of tax law. Our tax practice is both national and international in scope, with clients headquartered throughout the United States and abroad, including the world financial centers in Asia, Europe and South America.
With over 20 experienced federal and international income tax attorneys, our group has the broad range of tax skills necessary to help our clients manage their domestic and global businesses in an ever-changing business world. We have extensive experience providing business transaction, dispute resolution, tax legislation and regulatory services, both domestically and overseas. Our mission is to provide efficient and innovative solutions to appropriately manage and minimize U.S. and foreign taxation.
A significant role of our domestic tax practice is to structure and implement the tax aspects of matters handled through ENTERPRISE’s vibrant transactional practice. We have in-depth experience with virtually all forms of business transactions, from taxable and tax-free acquisitions, dispositions, and venture formations to financings and reorganizations. Our attorneys bring with them strong industry background and extensive experience in a variety of industries, including telecommunications, banking, real estate, insurance, manufacturing, financial services and the service industries generally.
We also have a national tax controversy practice that is expert in audits, administrative appeals, trial and appellate tax litigation at all levels of the federal court system, and mediation of both docketed and non-docketed cases. Our tax controversy specialists combine insight into substantive tax law and complex procedural options to effectively defend client positions through written and oral advocacy.
The firm’s Legislative and Public Policy Tax Practice contributes significantly to the firm’s reputation as one of the nation’s premier law firms. We provide our clients with a full range of services to help them participate in and shape the public policy debate before, rather than after, those decisions are made. Our clients take a proactive approach to tax policy development and we work to ensure that clients know about the latest tax issues as they develop.
ENTERPRISE’s international tax practice provides sophisticated advice with respect to both inbound and outbound transactions, investments and operations in an increasingly global economy. Our international tax practitioners advise on cross-border transactions, including multicountry acquisitions, dispositions, joint ventures and financings; real estate and private equity fund formation; transfer pricing matters, including development of pricing policies and methodologies; the negotiation and securing of advance pricing agreements (APAs); competent authority proceedings; international tax controversies; and all aspects of income and information exchange tax treaties. We have our finger on the pulse of evolving issues such as the base erosion and profit shifting (BEPS) project and other international initiatives.
ENTERPRISE’s federal and international tax lawyers are widely recognized as experts in the field. Our lawyers are leaders of various American Bar Association Tax Section Committees, including two former chairs of the Committee on U.S. Activities of Foreigners and Tax Treaties; a former chair of the Competent Authority Subcommittee of the Transfer Pricing Committee; the co-chair of the Subcommittee on Partnerships and Passthrough Entities of the Committee on Foreign Activities of U.S. Taxpayers; the vice-chair of the Tax Committee of the Business Law Section; and two past chairs and current vice-chair of the Committee on Banking and Savings Institutions. A number of our lawyers are members of the National Council of the International Fiscal Association (USA Branch).
Our attorneys frequently publish in a wide range of tax journals, including the Journal of Taxation, The Journal of International Taxation and the Tax Management International Journal. Lawyers in our group have written the BNA Tax Management Portfolio, “Income Tax Treaties – Administrative and Competent Authority Aspects” and the CCH Federal Tax Service Portfolio on “Effectively Connected Income and Branch Level Taxes,” as well as serving as the principal authors and editors of Practical Guide to U.S. Transfer Pricing.
Our attorneys include a member of the board of advisors of the Journal of International Taxation, two members of the editorial advisory board of the International Tax Advisor, a member of the advisory board of the Tax Management International Journal and a member of the editorial board of CCH’s Taxation of Global Transactions. A member of our group is one of a small number of U.S. lawyers invited to participate in the OECD Transfer Pricing Experts Advisory Meetings.
ENTERPRISE’s tax practice has consistently been rated among the best in the United States. A significant number of our lawyers are listed in The Best Lawyers in America, Euromoney’s Guide to the World’s Leading Tax Advisors and Chambers’ American Leading Tax Lawyers. Several of our attorneys have been elected Fellows of the American College of Tax Counsel.
Bringing Value to Our Clients
The strength of our practice group is borne of the depth of its collective, substantive knowledge, coupled with our attorneys’ knowledge of industry and business norms, strong client relationships and historically sophisticated deal flow and controversy work.
We provide practical, hands-on, senior level attention to our clients’ matters, and through our leadership positions, we gain access to current tax developments and tax officials on behalf of our clients. We also maintain strong global relationships with tax firms in all major countries, enabling us to provide our clients with on-the-ground international tax developments, as well as sophisticated tax expertise and advice on matters of foreign tax law affecting our clients’ cross-border transactions and operations.
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