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Our tax attorneys regularly advise clients on the tax aspects of corporate reorganizations, acquisitions, spin-offs and other dispositions, joint ventures, financings, and restructurings. These transactions frequently involve large multinational businesses and raise complex domestic and multinational tax issues. Tax considerations often determine the form and the viability of contemplated transactions. In current distressed market conditions, our tax group, working together with our corporate and restructuring and finance groups, frequently is called upon to participate in the restructuring of existing financial arrangements, including those arising out of private equity and other leveraged transactions. Our tax group also is involved in creating new financial products and in innovative real estate transactions and is considered preeminent in all of the areas in which it is involved. Members of our tax group regularly publish and lecture on emerging tax issues, and actively participate in the work of tax policy groups, such as the Tax Section of the New York State Bar Association and the International Fiscal Association. Examples of major recent transactions in which our tax expertise has played a critical role include: the acquisition by JPMorgan Chase of Bear Stearns; the acquisition by Bank of America of Countrywide; the acquisition by Bank of America of Merrill Lynch; the acquisition by Delta Air Lines of Northwest Airlines; the acquisition by NYSE Euronext of the American Stock Exchange; the sale of Alltel to Verizon Wireless; issuances of equity securities by Merrill Lynch, Ambac Financial Group, and Morgan Stanley; the spin-off by NCR of Teradata; the spin-offs by IAC/InterActiveCorp of Ticketmaster, Interval Leisure Group, HSN and Tree.com; the recapitalization and split-off of the Reinsurance Group of America by MetLife; representation of Kimco in its strategic alliance with Valad Property Group of Australia; and Public Storage in its joint venture with New York Common with respect to Shurgard Europe.
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