Ansgar A. Simon
Area of Practice
Stanford Law School, J.D., Order of the Coif, 1999; Managing Editor, Stanford Journal of International Law
University of California, Los Angeles, Ph.D, Philosophy, 1997
Mr. Simon has a broad-based transactional tax practice. He has extensive experience advising multinational enterprises, a large variety of alternative investment funds, and high net worth individuals on both inbound and outbound transactions. He regularly advises on mergers and acquisitions, corporate restructurings, divestitures (including spin-offs), and joint ventures, including transactions using flow-through entities and expatriation transactions. Mr. Simon also advises on the tax aspects of financing corporate transactions and the structuring of alternative investment vehicles. In addition, he regularly advises both U.S. and foreign clients on FATCA.
Recent transactional representations include: Javelin Global Commodities in the structuring of its worldwide commodities trading business (2015); Omnilife Holding Inc. in its sale of the Chivas USA soccer club to Major League Soccer (2014); Liberty Global plc in its $23.3 billion acquisition of Virgin Media Inc. and the related expatriation of Liberty Global Inc. to the United Kingdom (2013); Danone in various matters, including its acquisition of YoCrunch (2013); SunGard Data Systems, Inc. in preparing its tax-free split-off of its Availability Services operations (2011-13); the financing in connection with the acquisition of Cooper Industries plc and Eaton Corp by Eaton Corporation plc (2012); the underwriters in the bond offering in connection with the spin-off of AbbVie Inc. by Abbot Laboratories Inc. (2012); Vivendi/Universal Music Group in its acquisition and subsequent partial disposition of the EMI Music Group (2011 and 2012); SunGard Data Systems, Inc. in the disposition of its Higher Education business to a consortium of private equity funds sponsored by Hellman & Friedman (2012); Iluka Resources Limited in the exploration of various U.S. acquisitions (2011 and 2012); The Dow Chemical Company in the divestiture of its Styron unit to Bain Capital (2010); various sovereign investment funds in connection with investments in the United States; American Axle in its out-of-court restructuring (2009); Daimler AG in connection with the bankruptcy of Chrysler LLC and investment by Fiat in Chrysler Group LLC (2009); Aabar Investments PJSC in connection with its joint investment with Daimler AG in Tesla Motors (2009); The Dow Chemical Company in the tax structuring for its $17.4 billion joint venture with the Kuwait Petroleum Company (2008); Merrill Lynch in its acquisition by Bank of America (2008); DaimlerChrysler AG in its disposition of 80.1% of Chrysler Holding LLC to Cerberus (2007); and Citigroup in its acquisition of Old Lane Funds (2007).
Selected Professional Awards and Associations
Member of the Executive Committee of the Tax Section of the New York State Bar Association, co-chair of the subcommittee on cross-border M&A
Member of Tax Review
Member of the Tax Section of the American Bar Association
Member of the Board of Trustees of the German International School of New York
Chapter on United States (with Peter H. Blessing) in Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings (ed. Peter H. Blessing), Wolters Kluwer Law & Business (2012, 2013, update 2014/2015 forthcoming).
Chapter on United States in International Taxation of Low-Tax Transactions, Juris Publishing (2013, 2014)
International Tax Review: Sovereign Immunity: a US and European View (January 2012, with Peter H. Blessing); US Companies Seek UK Migration Benefits (June 2011, with Simon Letherman et al.).
Practical Law Company: FATCA Explained (March 2010); The Foreign Account Tax Compliance Act of 2009 Introduced (November 2009).
Recent presentations on tax aspects of foreign currency transactions and derivatives; expatriation transactions; subpart F and earnings repatriations; the dual consolidated loss regime; the sourcing of income; limitations on net operating loss carryforwards (section 382); and FATCA.
Goldman Sachs Hands Over Colombian Coal Mines to Murray (Latin Lawyer)
When is an Investment Manager Subject to Self-Employment Tax? (November 17, 2014)