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Global Tax

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Our clients look to us for guidance on a wide range of global tax issues. We advise corporations and their shareholders in connection with their offshore acquisitions and activities and in connection with international operations and acquisitions.

Case Studies

Rechtliche und steuerliche Aspekte von Mitarbeiterbeteiligungsprogrammen für Start-ups

2023 Tax Law Conference: Federal Bar Association

State Taxation of Digital Assets: Sales Taxation of Cryptocurrency and NFT Transactions

GoLegal! Crashkurs für Start-ups und Scale-ups: Steuerliche Aspekte der Internationalisierung

Go Legal! Start-up-Crashkurs zu ESOP, VSOP und Co. – Was bringt das neue Fondsstandortgesetz?

Start-ups in Zeiten von COVID 19 - Rückblick und Ausblick: 

Events

Share Deals: Geplante Änderungen im Hinblick auf die Grunderwerbsteuer

Share Deals: Planned Changes with Respect to Real Estate Transfer Tax

Referentenentwurf des Zukunftsfinanzierungsgesetzes veröffentlicht – Steuerfreiheit von Mitarbeiterbeteiligungsprogrammen in bestimmten Konstellationen bald möglich?

Draft of Future Financing Act Published – Tax-Free Share Schemes to Come?

German Federal Fiscal Court Confirms Its Special Concept Regarding the Attribution of Real Estate Property for Real Estate Transfer Tax Purposes—The Risk of Double Taxation Remains

First Draft of German Implementation of Global Minimum Taxation Published

Insights

Morrison Foerster Named a Finalist in Five Categories in ALB’s 2023 Hong Kong Law Awards

Morrison Foerster Named Firm of the Year in Five Practice Areas by China Business Law Journal 2023

Morrison Foerster recognized by the ACLU Foundation of Southern California with their annual Pro Bono Award

Prominent In-House Lawyer and Global Head of Tax Brian Radigan Joins Morrison Foerster

Morrison Foerster Awarded Impact Deal of the Year at the International Tax Review Awards 2022

Steuern nur aufgrund eines inländischen Registereintrags sind verfassungswidrig

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Bernie Pistillo is a partner in the San Francisco office of the firm’s Federal Tax Group. He regularly advises on the U.S. federal income tax aspects of international and domestic mergers and acquisitions, corporate restructurings and spin-offs, and tax controversy matters in the international area, particularly transfer pricing, the development and exploitation of technology and intellectual property and the structuring of international operations for both start-up entities and existing corporate groups. His practice involves the coordination of tax laws in multiple jurisdictions to develop and implement cross-jurisdictional tax planning, overall operational synergies and worldwide tax minimization strategies. He also is regularly involved in the negotiation of strategic joint ventures and partnerships and the structuring of private equity funds and their investments. Bernie also advises on financial product development and the tax aspects of financial institution and insurance company operations.Bernie is a member of the Dean’s Advisory Board at Tulane University School of Law, the Steering Committee of the Northern California Chapter of the U.S.A. Branch of the International Fiscal Association, the Planning Committee for the USC Gould School of Law Tax Institute, and the Tax Review and the Tax Club, both in New York City. He is admitted to practice in California, New York and Arizona.He is a frequent lecturer and author on matters relating to international taxation and corporate taxation generally.Bernie is recommended by Legal 500 US for US Taxes: Contentious, US Taxes: Non-Contentious and International Tax.Recent Client Transactions include:<ul><li>Softbank Corp. in connection with its $1 billion investment in WorldVu Satellites Ltd (OneWeb) and of SoftBank and OneWeb in connection with the negotiation and execution of an agreement pursuant to which OneWeb will merge with Intelsat SA in a share-for-share transaction.</li><li>Temasek Holdings Pte Ltd in making an $800 million investment in Verily Life Sciences (formerly Google Life Sciences), Alphabet’s health-focused subsidiary.</li><li>Boyd Gaming Corporation in the sale of its 50% equity interest, valued at $900 million, in Marina District Development Holding Company, LLC, the parent company of Borgata Hotel Casino & Spa in Atlantic City, New Jersey, to MGM Resorts International.</li><li>The co-founder of Broadcom Corp. in connection with its acquisition by Avago Technologies Ltd. in a cash and stock transaction with a combined enterprise value of $77 billion.</li><li>VMWare in planning a joint venture with EMC Corporation to form a new cloud services business, as well as in connection with the planned $67 billion acquisition of EMC by Dell Inc. using tracking stock of VMWare.</li><li>McKesson Corporation in numerous acquisitions in the healthcare and related areas.</li><li>SoftBank Corp. in connection with its acquisition of a 78% interest in Sprint Nextel for an enterprise value of $44.8 billion.</li><li>MicroPort Scientific Corp. in connection with its acquisition of the worldwide OrthoRecon operating segment of Wright Medical Group Inc.</li><li>Toshiba Tec Corp. on its $874 million acquisition of the worldwide retail store solutions business of IBM Corp.</li><li>Textainer Group Holdings Ltd. in connection with a review of its worldwide operating structure to improve financial and legal efficiencies.</li><li>Novellus Inc. in its tax-free stock-for-stock acquisition by Lam Research Corp valued at $3.3 billion.</li><li>Carlyle Group in its acquisition of Walbro Engine Management from Sun Capital Partners and related LBO financing</li></ul>

Bernie J. Pistillo

Partner

Anthony J. Carbone is a partner in our New York office and chair of the Federal Tax practice. His practice focuses on tax planning strategies and the tax consequences of a wide range of business, investment and capital markets transactions in the U.S. and internationally.He advises clients on all forms of mergers and acquisitions, reorganizations, fund formation and leveraged buyouts representing private equity funds, deal sponsors, investment banks, commercial banks and hedge funds, as well as venture capital, real estate and other funds (foreign and U.S.), acquiring and target companies, and management groups.Tony has extensive experience on the tax aspects of bankruptcy matters and has been involved in many high-profile matters. He also has extensive experience in the tax aspects of corporate finance transactions representing both financial institutions and their customers and clients. He advises banks and other offshore clients on the tax aspects of their U.S. and offshore business activities, and their offerings of securities and other financial products into the U.S. His experience includes foreign investments in the U.S. and abroad, international joint ventures and international finance transactions.Tony also has extensive experience in a wide variety of securities offerings, including complex debt securities, securitization transactions and derivatives. His expertise includes debt securities that contain an embedded derivative, including finance instruments with returns linked to various types of reference assets.Tony handles federal, state and local tax controversies involving both administration proceedings and litigation in federal and state courts. Tony has also been involved in a number of cases challenging the applicability and/or constitutionality of certain New York State and city tax provisions and has successfully had such proceedings transferred from the State Tax Administration Tribunal to the New York state courts.Prior to joining Morrison & Foerster, Tony was a tax partner at a large, international law firm based in New York and prior to that he was a partner at Bingham McCutchen LLP, where he was co-leader of the Tax Group, a former deputy chair of the corporate area, and co-managing partner of Bingham’s New York office. Tony is a member of the American Bar Association (Tax Section) and the New York State Bar Association (Tax Section). He is the former President of the New York Chapter of the Indiana University Kelley School of Business Alumni Association and has served as a member of the Board of Directors of the university’s alumni organization.Tony is a Certified Public Accountant.