World-renowned Tax Practice

Among the 2007 highlights for Sullivan & Cromwell’s Tax Group was its recognition by Chambers USA as “Corporate Tax Team of the Year.” The Tax Group has been ranked #1 in Chambers USA for five straight years, since the inception of this guide in 2003.

Our Firm’s tax lawyers continued to work closely with our M&A, securities, structured finance and bank regulatory lawyers to advise many of our clients on the structuring and issuance of tax-efficient hybrid debt and equity instruments—an area in which we are the undisputed leader. In 2007, our Firm’s tax lawyers assisted in structuring hybrid securities offerings for AIG, JPMorgan Chase, Merrill Lynch, Wachovia, Washington Mutual and Wells Fargo. Significant representations also included several high-profile transactions in recent months advising clients seeking to develop and/or participate in strategies to help major financial institutions enhance their capital bases after incurring substantial losses. These representations included advising:

• Citigroup on the structuring of the US$ 7.5 billion investment by Abu Dhabi Investment Authority; and
• China Investment Corporation on its US$ 5.6 billion investment in Morgan Stanley.

In addition, our tax lawyers were integrally involved in substantially all of the merger and acquisition matters handled by our Firm last year, including advising:

• AIG in its US$ 813 million acquisition of the remaining 39.2% stake in 21st Century Insurance Group;
• Amgen in the sale of its Japanese subsidiary, Amgen KK, to Takeda Pharmaceutical Company Limited, and in its acquisitions of Alantos Pharmaceuticals for US$ 300 million and Illypsa for US$ 420 million;
• Business Objects in its US$ 300 million acquisition of Cartesis, a domestic French transaction involving French tax matters; and
• Fiserv in its US$ 4.4 billion acquisition of CheckFree Corporation and in its $325 million sale of Fiserv Investment Support Services to TD AMERITRADE Holding Corporation.