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HEAD OF  DIVISION





LLC  TAXATION

TAX & PUBLIC LAW

Today, governmental efforts to increase or maintain tax revenue levels pose new and difficult challenges for tax planning and dispute resolution for corporations, partnerships, and individuals alike.

Sophisticated Advice

McAllister Davis & Goldstein’s international tax practice provides clients with sophisticated and practical advice on tax planning, tax strategies for transactions, cross-border issues and the resolution of difficult tax controversies.

Clients bring their most complex tax challenges to McAllister Davis & Goldstein. Tax issues can be exceptionally complex and our lawyers are experts in the finer points of tax law. Just as important, we are able to provide practical solutions to technical problems and explain complicated issues in a clear and understandable way.

Our tax lawyers typically join a deal team at the outset of a transaction, as early direction on tax issues is often critical for success. We pride ourselves on our ability to partner with clients to help them achieve their goals, with advice tailored to each client’s unique commercial and tax objectives. Our global tax practice is largely a transactional and financing practice. We provide sophisticated, deal-specific tax advice that allows our clients to accomplish their commercial objectives on a tax-efficient basis.

International Tax Practice

With tax attorneys resident in the United States and Europe, the firm is capable of providing advice in various jurisdictions on a multitude of issues. We are one of the few international law firms that provides a combination of both domestic and cross-border tax advice within the major European jurisdictions.
For those jurisdictions in Europe in which we do not have attorneys resident or licensed, we have established a network of local counsel to whom we refer matters.
Our tax lawyers in the United States advise both U.S. companies investing abroad and non-U.S. investors in the United States. Similarly, our tax lawyers in Europe advise local clients on the national tax impacts of their international transactions. We pride ourselves on working together as one integrated team.

Our Tax Group

Our tax group works cooperatively across the firm’s international offices, comprising an integrated worldwide tax practice that serves multinational industrial clients, financial institutions, investment funds and individuals in matters including:

  • Cross-border direct investments
  • Domestic and multinational mergers, acquisitions and joint ventures
  • International capital markets transactions
  • Investment funds, including private equity funds and hedge funds
  • Restructurings and bankruptcies
  • Tax controversies, investigations and litigation
  • Tax planning for multinational enterprises


Our extensive deal experience and deep bench allows us to provide real-time advice that takes into account current tax developments. We regularly counsel clients across multiple jurisdictions in connection with acquisitions and dispositions of global business operations, spin-offs, joint ventures, financings, and offerings of both debt and equity.

Tax Disputes

McAllister Davis & Goldstein’s tax team also effectively represents clients in tax disputes and provides skilled and experienced advocacy on behalf of clients at every stage of the tax controversy process, from pre-audit planning, to audit through administrative appeals and post-appeals mediation, in competent authority matters, and in tax litigation.


Guernsey enacts OECD Rules

Guernsey recently approved legislation to implement the
OECD’s Pillar Two rules, effective from 1 January 2025.
The Pillar Two rules ensure that large multinational
enterprises with a consolidated annual turnover exceeding
EUR 750 million (MNE) pay a minimum tax of 15% at a
jurisdictional level, with a top-up tax on any low-tax profits.


The corporate income tax rate in Guernsey will remain at 0%. The 15% minimum
effective tax rate applicable under the Pillar Two legislation will only apply to
MNEs meeting the consolidated turnover threshold.