McDermotts State and Local Tax Capabilities McDermott Will & - PDF document

McDermott’s State and Local Tax Capabilities McDermott Will & Emery has one of the largest and most diversified state and local tax (SALT) legal practices in the United States. Our lawyers SCOPE OF PRACTICE possess an in-depth knowledge of the constantly changing tax laws, as • Business license tax well as the experience and judgment necessary to provide advice and • Commercial rent and occupancy tax advocacy of the highest caliber to our clients. The members of the group • Corporate income tax are nationally recognized as experts and, as such, are consistently sought • Document and stamp tax as speakers at seminars and conferences conducted by numerous tax • Economic development incentives and business organizations throughout the country. • Employment withholding tax • Franchise tax Experience • Fuel use tax • Highway use tax Initially launched as a tax law firm in 1934, McDermott brings a wealth of • Hotel occupancy tax history and experience to the tax arena (our lawyers, for example, • Intangible personal property tax successfully litigated the only two Supreme Court victories in the “unitary” • Liquor tax area as well as the landmark Quill case in the sales tax area). Our team is • Mortgage recording tax especially skilled in the myriad state and local tax issues generated by the • Personal income tax ever-growing internet and e-commerce segment of the world’s economy. • Real estate transfer tax We focus on identifying and developing solutions for our clients’ particular • Sales and use tax tax concerns regardless of the jurisdiction, issue or procedural stage • Telecommunications tax involved, and work closely with colleagues across the Firm to provide • Tobacco tax seamless service. We are also able to draw upon our many state contacts to assist clients effectively and efficiently. Planning & Transactions Our SALT practice provides planning services related to existing business relationships and practices (structural planning) as well as to specific pending transactions (transactional planning). Working with the client’s staff, our lawyers determine where proactive changes can be made to improve the client’s state and local tax situation. One set of tax costs that is often overlooked when planning transactions is the imposition of state and local taxes (such as sales and real estate transfer taxes) on the transaction. Our lawyers not only assist clients in avoiding these hidden pitfalls, but also help them achieve greater tax efficiency in their post-transaction operations. Legislative Initiatives & Lobbying Although traditional legal avenues such as planning, settlement and litigation are often the best courses of action to achieve the desired results for our clients, in some instances these are either unavailable or foreclosed under existing laws or regulations. In those instances, we offer legislative and lobbying initiatives to help achieve the desired results. Our services include monitoring specific issues and legislative initiatives, building consensus with other interested parties, preparing proposals, drafting legislation and communicating proposals to the legislative decision-makers. AWARDS & ACCOLADES • Named 2016 “Tax Law Firm of the Year” by U.S. News & Best Lawyers • Nationally ranked in Chambers USA 2016 in Tax Controversy and Tax (Corporate and Finance) • Named “Tax Practice Group of the Year” by Law360 (2015) • McDermott received top tier rankings in Tax: Financial Products, Tax: International Tax and Tax: Controversy by The Legal 500 20150

McDermott’s State and Local Pre-Litigation & Tax Controversy Capabilities As the IRS increases its pursuit of big-ticket issues, national and multinational corporations require immediate, sophisticated responses from legal advisors with a significant understanding of the methods and goals of the IRS and the skills and experience to mount an effective defense. McDermott’s Tax Controversy practice is notable for the sophistication and skills of our team, the depth of our experience and our proven track record of delivering results for clients. Our lawyers regularly represent some of the world’s largest corporations on complex tax issues, often with hundreds of millions of dollars under scrutiny. We efficiently develop the critical facts, construct the most effective arguments and work closely with our clients in charting the best course for resolving any matter. No matter whether the course is to resolve the controversy at the audit or administrative review level or to litigate the case to the highest court, we have the experience, skill, passion and relationships to accomplish the goal.  Our group prides itself on zealously representing our clients; our fight-to-win advocacy approach is handled in a manner that retains relationships with state tax administrators while professionally agreeing to disagree  We focus on identifying and developing solutions for our clients’ particular tax concerns regardless of the jurisdiction, issue or procedural stage involved  We have handled cases involving income, franchise, sales/use, and other transaction taxes  We have handled state tax controversy matters in approximately 48 states, the District of Columbia and the US Supreme Court  Routinely collaborate with McDermott’s top-ranked US and International Tax, Trial, Corporate and Benefits Groups to deliver truly comprehensive, integrated service International Reach Dedicated to alleviating any and all tax burdens our clients may face, our lawyers in China, Germany, Italy, France, the United Kingdom and the United States allow us to analyze and resolve legal issues from various angles. We provide ongoing advice to multinational businesses regarding US federal and state income tax rules applicable in Europe and China. We are equipped to handle tax matters relevant to international operations, such as controlled foreign corporations, acquisitions and dispositions, currency, tax credits and general foreign taxation. We also handle real estate transfer tax matters and value-added tax issues. In addition, we counsel on the reduction of worldwide tax rates, structuring start-up operations, restructuring global operations and transfer pricing. We have organized and chair the Transfer Pricing Discussion Group , whose members include key US- and foreign-based multinationals from various industries. Extending our international reach even farther is McDermott’s International Tax Panel , which includes leading tax attorneys at firms in Europe and the Americas.

State and Local Tax Team Fred M. Ackerson Catherine A. Battin Richard C. Call Partner, Chicago Partner, Chicago Partner, Boston +1 312 984 6929 +1 312 984 3233 +1 617 535 3974 fackerson@mwe.com cbattin@mwe.com rcall@mwe.com Eric D. Carstens Roy E. Crawford Tom H. Donohoe Associate, DC Counsel, Silicon Valley Senior Counsel, Chicago +1 202 756 8353 +1 650 815 7418 +1 312 984 7797 ecarstens@mwe.com rcrawford@mwe.com tdonohoe@mwe.com Lauren A. Ferrante Nick Furtwengler Peter Faber Associate, Chicago Associate, Chicago Partner, New York +1 312 984 2053 +1 312 984 7677 +1 212 547 5585 lferrante@mwe.com nfurtwengler@mwe.com pfaber@mwe.com Andrew Greiner Stephen P. Kranz Mary Kay Martire Associate, New York Partner, DC Partner, Chicago +1 212 547 5777 +1 202 756 8180 +1 312 984 2096 agreiner@mwe.com skranz@mwe.com mmartire@mwe.com Jane Wells May Alysse McLoughlin Kathleen M. Quinn Partner, Chicago Partner, New York Associate, New York Head, State & Local Tax +1 212 547 5307 +1 212 547 5718 +1 312 984 2115 amcloughlin@mwe.com kquinn@mwe.com jmay@mwe.com Arthur R. Rosen Diann Smith Scott Susko Partner, Miami, New York Counsel, DC Partner, Boston +1 617 535 3866 Miami: +1 305 347 6512 +1 202 756 8241 ssusko@mwe.com New York: +1 212 547 5596 dismith@mwe.com arosen@mwe.com Mark Yopp Partner, New York +1 212 547 5798 myopp@mwe.com

The McDermott Difference McDermott is a premier international law firm with a diversified business practice. Numbering more than 1,100 lawyers, we have offices in Boston, Brussels, Chicago, Dallas, Dusseldorf, Frankfurt, Houston, London, Los Angeles, Miami, Milan, Munich, New York, Orange County, Paris, Rome, Seoul, Silicon Valley and Washington, D.C. Further extending our reach in Asia, we have a strategic alliance with MWE China Law Offices in Shanghai. McDermott has 80+ years of serving a broad range of client interests. The expansion of our international platform has supported numerous cross-border transactions and litigation matters, while providing the experience necessary to offer corporate and commercial, international and state and local tax, labor and benefits, competition, intellectual property and regulatory counsel to clients across all jurisdictions and industries. Our culture is characterized by teamwork, mutual respect and a commitment to excellence in everything we do. Outstanding client service is a cornerstone of our practice that has withstood the test of geography, economy and time. We are proud of the recognition we have received from our clients for our commitment to service, and we value their satisfaction as the best measure of our success. QUICK FACTS • Named one of Working Mother & Flex-Time Lawyers “50 Best Law Firms for Women” • Received the Minority Corporate Counsel Association’s (MCCA) 2014 George B. Vashon Innovator Award for our Diversity Talent Development Initiative. • Named a Best Place to Work for LGBT employees by Human Rights Campaign every year since 2006 • Ranked 12th on Law360’s list of the “100 Best Law Firms for Minority Attorneys”