Overview

Corvane Ryle's Tax practice advises on the tax aspects of the transactions, financings, restructurings and operating models that our clients run. We work as part of the deal team, not alongside it, so that tax is considered when a structure is chosen rather than after it is signed.

Our lawyers advise on the tax treatment of mergers, acquisitions, spin-offs, joint ventures and fund formations, and on the structuring of debt and equity offerings. They know where value hides in a transaction: tax attributes, basis step-ups, transfer taxes, withholding and the allocation of risk in a purchase agreement. In private equity and infrastructure, we advise on blocker and holding structures, carried interest and exit planning.

International tax is changing quickly. The OECD's Pillar Two global minimum tax rules are in effect in many jurisdictions, including EU member states and the UK, and multinationals are working through compliance, safe harbors and the interaction with US rules. We advise on this and on transfer pricing, intellectual property migration, repatriation and the tax consequences of moving operations across borders.

Our energy transition clients rely on us for the structuring of tax credit transactions, including transferability arrangements and tax equity, and for advice on how changes in US legislation affect project economics. When a dispute arises, we represent clients before the IRS, in examinations and appeals, and in tax litigation.

Arjun Mehra-Collins leads the practice from New York, working with tax partners in Chicago, London, Frankfurt and Singapore. We advise clients in retail, technology, energy and financial services, including Solenne Energy.

Key lawyers

Our tax team is led from New York and works inside the firm's deal and finance practices.

• Arjun Mehra-Collins, Partner, New York

Representative experience

• Advised Solenne Energy on the tax structuring of a 900 MW solar portfolio financing.
• Counseled Halvern Retail Group on the tax aspects of its acquisition of Brightmoor Foods.
• Advised a multinational consumer products group on Pillar Two implementation across 40 jurisdictions.
• Structured a tax equity partnership for a wind developer with a transferability component.
• Advised a sponsor on the tax-efficient carve-out of a division from a listed parent.
• Represented a technology company in an IRS transfer pricing examination.
• Advised a European fund on the tax structure of a US infrastructure investment.