企业所得税

Tax structuring for clients involved in mergers and acquisitions is an important part of Orrick’s extensive corporate tax planning capability.

Tax Department lawyers have been involved in domestic and international transactions involving purchases and acquisitions, business combinations and divestitures, corporate restructuring such as recapitalizations, multi-tier spin-offs and split-offs and hybrid entities, and innovative transactions involving the consolidated return regulations.

Orrick’s Tax Department offers services to address clients’ corporate tax needs in:

Asset-based Securitizations
Compensation and Option Plans
Consolidated Return Regulations
Corporate Restructuring
Cross-border Transactions
Distressed Debt
International Sale Leasebacks
Joint Ventures
Mergers and Acquisitions
Multi-tier Spin-offs and Split-offs
Project Financing
Recapitalization
Tax Counseling

交易经验

Aladdin Capital Holdings

Orrick provided tax advice regarding the formation of the Aladdin Citation Fund, a long-short relative value credit fund that was formed using a traditional master-feeder structure.

Credit Suisse

Representation of Credit Suisse as tax counsel in connection with issuance of approximately 100 structured notes which had returns based on the value of equities, commodities and foreign currencies.

Korea Development Bank

Representation of Korea Development Bank in the financing of acquisition of Acushnet.

Paddock Laboratories

Orrick represented generic drug maker, Paddock Laboratories, in the sale of its assets to Perrigo Co. for $540 million. Orrick was tax counsel for Paddock and worked on the structuring of the transaction, as well as the negotiation of the tax aspects of the Asset Purchase Agreement for the transaction..

Telenor ASA

Orrick represented Telenor ASA, a public Norwegian telecom company, in connection with the $23.8 billion combination of Telenor and Altimo's interests in VimpelCom, a Russian telecom company, and KyivStar, a Ukrainian telecom company, in the newly formed VimpelCom Ltd., a Bermuda corporation resident in The Netherlands. The transaction was in settlement of certain litigation between the parties.

Total SA

Representation Total, Europe’s largest refiner of in connection with a joint venture with Amyris Inc. to produce and sell diesel and jet fuel made from plants

U.S. Corporation

Orrick represented a U.S. corporation (name confidential) regarding the $245 million acquisition from a French conglomerate of certain assets and subsidiaries. The transaction related to subsidiaries and assets in nine countries and involved a number of cross-border tax issues.