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Most Highly Regarded Firms: California 2009 - Corporate Tax

This chapter identifies 18 leading tax lawyers at 13 firms in California.

We have focused on experts with a wide range of specialisations; international tax specialists as well as domestic experts, direct and indirect taxation practitioners, transfer pricing specialists, as well as those who focus on tax issues deriving from mergers, acquisitions and dispositions.

Irell & Manella LLP is a prominent Californian firm that has traditionally been very strong on tax law and continues to be so: we identify three of its lawyers in this chapter. Milton Hyman is a "brilliant federal tax lawyer", who focuses on the complex tax matters relating to business planning and in major acquisitions and combinations. Hyman headed the teams responsible for the Thrifty-Payless drug stores as well as representing Broadcom in a number of acquisitions. He also has significant experience handling tax controversies. Elliot Freier specialises in the federal and state taxation of corporations and is "very sharp and on the ball". He is a keen speaker and has lectured to the Internal Revenue Service's office of chief counsel on corporate on bankruptcy tax issues. Joel Rabinovitz served as deputy international tax counsel at the US Department of Treasury prior to joining the firm. He is well known for his knowledge of partnerships and his international tax-planning work.

Fenwick & West LLP offers clients tax advice on planning, transactional issues and litigation. It represents over 40 of the Fortune 100, as well as large non-US companies, in federal tax matters. Major clients include Electronic Arts and Cisco and the firm has recently been involved in both the Adaptec and Xilinx cases. James Fuller chairs the tax group. He was especially praised for his transfer pricing work, having represented companies such as Apple Computer, Hitachi and DHL. Fuller and his team are called on to review and evaluate existing and potential transfer pricing and cost sharing disputes and to provide oversight and strategic guidance. Fuller is "a luminary" and "one of the real stars in California - considered to be as knowledgeable as anyone in the country". The similarly well-regarded Walter Raineri was lead counsel in the aforementioned Adaptec transfer pricing and cost sharing case. He was described as a "key name at a prominent firm" who is "well known and well liked".

Latham & Watkins LLP also boasts two entries in this edition. The Los Angeles office is home to managing partner John Clair and the "brilliant" Laurence Stein. Clair advises clients on the tax issues involved in mergers, acquisitions and divestitures, financial products and services, as well as administrative and judicial tax controversy matters. He also has a respected international aspect to his practice, representing non-US corporations. Stein is global chair of the firm's tax department and a "recognised authority", speaking before organisations such as the Tax Executives Institute, the New York University Institute on Federal Taxation and the University of Southern California Tax Institute.

Baker & McKenzie LLP is the last firm to have two partners listed in this chapter. John Peterson is chair of firm's global tax group. His practice places great emphasis on inter-company pricing and the structuring of international operations and he is comfortable dealing with high technology tax issues and federal income tax controversies. He was also praised during our research as "great for state and local tax" and is a certified public accountant. Gary Sprague is "just great" and advises software, high-technology and e-commerce companies. He is a prolific writer and also speaks frequently on a variety of international tax-planning topics.

Ivan Humphreys is one of the most highly nominated practitioners in our research. He is based in the Palo Alto office of Wilson Sonsini Goodrich & Rosati, a firm that specialises in representing technology and growth businesses. Humphreys is regarded highly for his domestic and international work relating to mergers and acquisitions, restructurings, financings and the formation of partnerships and limited liability companies.

Munger Tolles & Olson LLP is home to Stephen Rose, a "top-class" professional in the eyes of his peers. Rose has tax controversy experience and his practice also attracted attention for his understanding of the interaction between corporate and partnership taxation, and in structuring creative, tax-favoured acquisitions and dispositions involving joint ventures. Thomas Steele chairs the West Coast state and local tax practice group at Morrison & Foerster LLP. Steele is a seasoned litigator and was counsel of record in the United States Supreme Court proceeding involving Farmer Brothers, as well as other high-profile matters. He has also carved out a niche counselling clients on the tax aspects of new forms of communications technology, advising a number of large telecommunications and new technology companies.

The "very smart" Terence Cuff from Loeb & Loeb LLP is another practitioner who performed exceptionally well in this year's survey. Cuff's client base predominantly consists of real estate investment trusts and investors, energy companies, corporations with transactional tax problems and financial institutions. He writes frequently on partnership and real estate taxation. Paul Sax is senior counsel in the San Francisco office of Orrick Herrington & Sutcliffe LLP. Sax's practice focuses upon tax planning and litigation for domestic and international clients. The former chair of the tax group is also an authority on the ethics and standards of tax practice.

Nancy Iredale from Paul Hastings Janofsky & Walker LLP is a "name you hear a lot", her strong reputation is reinforced by her appointment to the commissioner of the Internal Revenue Service's advisory group. Iredale's reputation as a "consummate litigator" in the tax field has seen her obtain summary adjudication for clients in tax controversies. Stephen Tolles from Gibson Dunn & Crutcher LLP is widely "viewed as one of the best in the business". Tolles's practice focuses on federal income and California taxation and he boasts considerable experience in matters involving private equity fund formation, complex financial instruments, roll-up transactions and publicly traded partnerships.

Julie Divola is chair of Pillsbury Winthrop Shaw Pittman LLP's San Francisco tax practice. She has served as outside tax counsel for Vodafone and its predecessor, AirTouch Communications. She has also served as outside tax counsel for Electronic Arts in connection with a variety of tax matters, including its acquisitions of VG Holdings, JAMDAT Mobile and Digital Illusions. Charles Moll leads Winston & Strawn LLP's nationwide state and local tax practice. Moll was part of the team that represented Bank of America's Strategic Investments Group in an $88 million acquisition of 50,000 acres of redwood timberlands. He also represented Soka University in litigation against the county of Los Angeles and the state board of equalisation.

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It is not possible to buy entry into any Who's Who Legal publication

Nominees have been selected based upon comprehensive, independent survey work with both general counsel and private practice lawyers worldwide. Only specialists who have met independent international research criteria are listed.

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