Stephan Harris designs and implements various reorganization, disposition, and acquisition transactions, including inversion transactions, domestic combinations, foreign-to-foreign redomiciliations, spin-off transactions, target bundling, and post-acquisition integration. He provides buy and sell side transactional tax design and guidance to M&A deal teams, including advice on acquisition form and structure, deal terms, SPA/APA representations, warranties, and indemnities, and SEC disclosures, as well as negotiation with opposite counsel.
Additionally, Stephan advises private equity firms and special purpose acquisition companies regarding inbound and outbound investments, provides tax planning and distribution planning to portfolio companies, as well as providing advice with respect to intangible property, deferral, tax attribute and repatriation planning, including guidance under Subpart F and GILTI. He has provided tax planning and distribution planning to portfolio companies and represents clients throughout various phases of deal litigation, including SPA/APA litigation and settlement of buy and sell side tax matters.
