Raymond J. Wiacek | 弁護士

Ray Wiacek is one of the world's leading international tax lawyers. He represents multinational corporations on cross-border financings, international acquisitions and reorganizations, and transfer pricing. He is particularly skilled at global planning involving intellectual property. Ray also defends his advice, favorably resolving tax disputes ranging from the proper pricing of foreign autos to the effectiveness of an agreement to share R&D costs worldwide. He is currently challenging the IRS' anti-inversion regulations in court.

Ray negotiated and closed billions of dollars of cross-border financings for Bank of America against many of the leading banks in Europe. He led the worldwide team integrating Warner-Lambert and Pharmacia with Pfizer after Pfizer's overhaul of those companies. This included the disposition of nonstrategic assets, such as Schick and Wilkinson Sword to Energizer and Chiclets and Dentyne to Cadbury. Ray also led the team that implemented a worldwide business and tax plan for Halliburton.

In addition to Bank of America, Pfizer, and Halliburton, representative clients have included Bridgestone/Firestone, Celgene, Dow Corning, H.J. Heinz, Isuzu Motors, JP Morgan, Transworld Oil, and United Coal.

Ray has testified many times on international tax matters before Congress and the Internal Revenue Service. He has been listed every year in the Chambers guide to best lawyers, with clients describing him as "pragmatic and deal oriented," "an excellent negotiator," with "superb technical skills and analytic ability."

担当案件

Cineworld Group completes asset monetization strategies in United States through cinema sale-leaseback transactionsJones Day advised UK headquartered, Cineworld Group PLC in connection with an asset monetization strategy in the United States involving a combined cash consideration of $556.3 million cinema sale-leaseback transactions to convert a substantial portion of Cineworld’s U.S. real estate holdings into cash to leverage its equity and optimize efficiency.

Daiwa Securities Capital Markets Korea, DBS Bank Limited, Mizuho Securities Asia, and Standard Chartered Bank act as arrangers in $350 million Floating Notes offering of KAL ABS 23 Cayman LimitedJones Day acted as United States corporate and tax counsel to Daiwa Securities Capital Markets Korea Co., Ltd., DBS Bank Limited, Mizuho Securities Asia Limited, and Standard Chartered Bank, as joint lead arrangers, in connection with the offering of $350 million Secured Floating Rate Notes due 2021 of KAL ABS 23 Cayman Limited.

Business groups obtain invalidation of IRS anti-inversion regulationsJones Day achieved a major victory on behalf of the U.S. Chamber of Commerce and Texas Association of Business when the U.S. District Court for the Western District of Texas invalidated temporary regulations that the IRS promulgated last year to deter a type of corporate transaction known as an "inversion.

Monolithic Power settles with U.S. Internal Revenue ServiceJones Day represented Monolithic Power Systems, Inc. in negotiating a settlement with the IRS Appeals Office of a dispute arising from the government's audit of the client's cost-sharing arrangement with its foreign subsidiary.

Pfizer reaches agreement with Boehringer Ingelheim to divest animal health assets in connection with regulatory approval processJones Day represented Pfizer Inc. in its recently announced agreement with Boehringer Ingelheim to divest certain animal health assets in connection with the regulatory approval process associated with Pfizer's pending acquisition of Wyeth.

Pfizer is involved in joint venture with GlaxoSmithKline to create new world-leading HIV company focused on research, development and commercialization of HIV medicinesJones Day represented Pfizer, Inc. in its agreement with GlaxoSmithKline plc to create a new world-leading HIV company focused solely on research, development and commercialization of HIV medicines.

January 2018 Jones Day Publications

EU Rules Starbucks, Fiat Received Tax Advantages from The Netherlands and Luxembourg Constituting Illegal State Aid, Must Pay Back Taxes

September 2015 Jones Day Publications

June 13, 2019
The Four Acts of an IRS Controversy: Act II - Uncommon Strategies for Dealing with the IRS Appeals Office
February 20, 2018
Jones Day's 2018 Speaker Series: The Tax Cuts and Jobs Act of 2017
April 20, 2017
Preparing for a Sea Change: A Conference with the Government and Private Sector to Discuss Comprehensive Tax Reform
February 22, 2016
Taxation and European Union State Aid Law: The European Commission's Investigation Into Whether Certain Tax Rulings Constitute State Aid
June 2015
2015 Tax Executives Institute Region III Conference, Foxwood Resorts and Casino
March 2015
BIO Conference on International Taxation in the Biopharmaceutical Industry
April 2014
Combating Tax Avoidance and Evasion, American Society of International Law Annual Conference
February 7, 2013
Executive Roundtable Series - Understanding the Impact of the New Tax Law and Formulating M&A and Growth Strategies in 2013 and Beyond
September 30, 2010
2010 Transaction Update
July 23, 2009
International Business Roundtable: Pittsburgh in the Global Economy - Doing Business in Europe, Asia, Mexico, and the Middle East

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担当案件

The U.S. Tax Cuts and Jobs Act: Fundamental Changes to Business Taxation

House of Representatives Releases First Draft of Tax Reform Bill

U.S. Tax Reform Proposal Highlights Potential Sweeping Changes

Trump Administration Proposes Substantial Reduction in Business and Individual Income Taxes

Regulatory Developments Life Sciences Companies Should Expect in the New Presidential Administration

Treasury Publishes Updated Model Income Tax Treaty

EU Rules Starbucks, Fiat Received Tax Advantages from The Netherlands and Luxembourg Constituting Illegal State Aid, Must Pay Back Taxes

Addressing the Tax Challenges of the Digital Economy: BEPS Action 1, Global Tax Update

BEPS Likely to Have Significant Impact on International Tax Rules, Global Tax Update

Countering Harmful Tax Practices: BEPS Action 5, Global Tax Update

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