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Davis Polk & Wardwell LLP has aclient roster that includes corporate giants across diverse industry sectors, among them Citigroup, Comcast, JPMorgan, and Pfizer. The tax practice handles advisory and contentious work ranging from partnership taxation, and contentious international  matters, to interest capitalization and allocation, withholding taxes, and foreign tax credit issues. It is actively involved in complex transfer pricing cases with values multibillion-dollar sums at stake, and it has an outstanding track record of success before federal and state courts, as well as matters handled at administrative level. Head of the tax group Mario Verdolini handles administrative proceedings and settlements, trials, and appeals, as well as advising on risk management issues. Christopher Baratta frequently assists domestic and foreign clients in the financial services, securities, manufacturing, media, software, and pharmaceutical sectors. Together, they advised multiple clients on potential refund claims based on the Tax Court’s ruling in the Varian case, which invalidated a regulation.
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Kernmandanten

  • Citigroup
  • Comcast

Highlight-Mandate

  • Served as lead trial counsel for Exxon Mobil Corporation in litigation concerning the tax treatment of a 2006 transaction with the State of Qatar.
  • Successfully defended Bausch Health against a $2 billion IRS tax claim relating to a Granite Trust transaction.