Mr. Dantzler's mergers and acquisitions experience includes numerous tax-free transactions in which White & Case provided the enabling tax opinion. Many of these transactions were cross-border acquisitions which required special structures, such as Canadian exchangeable shares. Some transactions have required unique structural solutions to accommodate the needs of sellers or to position the acquiring company for future tax savings.
Mr. Dantzler has led a number of internal restructuring projects for global clients. These projects have included tax planning for the ownership and utilization of intellectual property and many of them have involved advice under US and non-US tax laws as to the optimal supply chain. Such projects typically require the talents of a team of White & Case tax lawyers in our offices around the world.
Mr. Dantzler also advises clients on the structuring of international and other transactions. He serves as principal outside tax counsel to several US public companies, and in that capacity advises all levels of management on a wide variety of tax issues. He also has extensive experience in advising non-U.S. companies which are forming or recapitalizing US subsidiaries and branches.
Mr. Dantzler is well-known for his extensive involvement in transfer pricing, as well. He represented a non-US automobile company in one of the first major US transfer pricing cases involving a treaty country. More recently, Mr. Dantzler has represented a major pharmaceutical company, a US high-technology company and others in transfer pricing controversies. He also advises clients on the avoidance of such controversies. In addition to transfer pricing, Mr. Dantzler has worked on a wide variety of domestic and international tax controversies, including valuation and capitalization issues. He has led successful defenses to attacks by the US Internal Revenue Service on leveraged leases, captive insurance arrangements and cross-border financial products.
Mr. Dantzler is a frequent speaker on tax matters, and in recent years has addressed groups in the United States, Mexico, Canada, France, Italy, Japan and Puerto Rico.