Andrew Solomon was elected as partner of Sullivan & Cromwell in 1992. Mr. Solomon served as the managing partner of the Firm’s Tax Group for 17 years and became Of Counsel in 2015. He has had a broad-based practice, involving both tax planning and dispute resolution and coordinated the Firm’s tax practice worldwide from offices in New York and London.
Mr. Solomon has been active in structuring and restructuring acquisitions, divestitures (including spin-offs) and joint ventures, especially cross-border transactions. He was instrumental in advising many clients about tax issues arising in connection with the last (2008) financial crisis and their restructuring in response to the crisis. He has also assisted clients in obtaining rulings and other administrative relief from the Internal Revenue Service, and in connection with Internal Revenue Service audits and controversies (at the IRS Appeals Office and in court).
Mr. Solomon has worked closely with, and is familiar with the particular cross-border tax issues affecting, global industrial companies, technology and other companies that license intellectual property, natural resource companies (including both mining and oil and gas companies) and private equity and hedge funds.
He also has had extensive experience advising financial institutions, including insurance companies, as well as banks and securities and commodities dealers. He is highly regarded for the quality of his advice on the taxation of complex financial products and has helped many clients with the design and implementation of those products.
Publications and Professional and Not-For-Profit Activities
- University of Miami School of Law, Graduate Tax Program, Member of the Faculty (adjunct). Course taught include:
- International Transactions: Europe, a course that provides an introduction to European Union tax law and how tax planning for U.S. multinational groups is affected by foreign tax law.
- The Digital Economy and International Taxation - National and International Responses, a course that considers the responses of various nations and international organizations to globalization, the increasing importance of intellectual property and ‘digitalization’ of the global economy, including the extensive work of the OECD, various national attempts to tax cross-border “digital transactions” and the response of the United States to these initiatives.
- Corporate Tax II.
- Executive Committee of the New York State Bar Association’s Tax Section – Member-at-Large: former Co-chair of the Committee on “Outbound” Activities of US Taxpayers; former Co-chair of the Committee on Treaties and Intergovernmental Agreements; and former Co-chair of the Committee on Financial Intermediaries
- Member, Planning Committee, University of Chicago Tax Conference
- Publications include:
- “OBBBA: A New Era in Republican Tax Legislation”, (Co-Author, Tax Journal, August 1, 2025)
- “OBBBA: Permanent Tax Cuts and International Adjustments” (Co-Author, Tax Journal, July 11, 2025)
- “The Big, Beautiful Bill: One House Down, One House to Go” (Co-Author, Tax Journal, June 13, 2025)
- “The Clock is Ticking on President Trump's Tax Bill” (Co-Author, Tax Journal, May 14, 2025)
- “Buckle Up Your Seatbelts: Why 2025 will be a Bumpy Ride for US Tax Policy (Co-Author, Tax Journal, January 23, 2025)
- “What Does the Future Hold for US Adoption of the OECD’s Two-Pillar Proposals?” (Co-Author, Tax Journal, September 19, 2024)
- “The Inflation Reduction Act 2022: Less than Promised?” (Co-Author, Tax Journal, October 6, 2022)
- What Next for US tax Policy?” (Co-Author, Tax Journal, January 21, 2021)
- “US Tax Reform: Outbound Investment,” (Co-Author, Tax Journal, February 22, 2019)
- “US Tax Reform: Inbound Investment. The latest on interest deduction limitations and the BEAT rules,” (Co-Author, Tax Journal, February 15, 2019)
- Dual Consolidated Loss, Tax Management Portfolio No. 6650 (Co-Author, Bloomberg BNA, November 2018)
- “The Corporate Tax Base: US and UK Tax Reform –Where Next?” (Panelist, 21st Cross Atlantic and European Tax Symposium sponsored by the Chartered Institute of Taxation and the British Branch of the International Fiscal Association, London, November 17, 2017)
- “PFICs – The Recurring Nightmare?” (Speaker, International Tax Institute Luncheon Seminar, New York, September 26, 2017)
- “What Does Mr. Trump’s Election Mean for the Future of International Taxation” (Speaker, Conference sponsored by the American Chamber of Commerce in Italy and Ludovici Piccone & Partners, Milan, February 14, 2017)
- New York State Bar Association Tax Section Letter 1362 Commenting on Reserved Portions of FATCA Final Regulations: Foreign Passthru Payments Withholding (Principal Draftsperson, January 19, 2017)
- “FATCA” (Panelist, 4th Annual International Bar Association Tax Conference: Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets, London, February 10, 2015)
- “Tax Issues Relating to Intangibles” (Panelist, 68th Congress of the International Fiscal Association, Mumbai, India, October 14, 2014)
- “FATCA: Where Are We Now, and What Next?” (Co-author, Journal of Taxation and Regulation of Financial Institutions, September/October 2014)
- "Passive Foreign Investment Companies (PFICs)" (Member of the Faculty, Practicing Law Institute course on Basics of International Taxation, 2014, New York City, July 22, 2014)
- Tax implications for non-U.S. banks in complying with the Dodd-Frank Act and Volcker Rule (Panelist, Annual Tax Seminar of the Institute of International Bankers, New York, June 18, 2014)
- "e-Commerce: The Cloud and BEPS” (Moderator and Panelist, 2014 Joint Canada-USA International Tax Conference, sponsored by the Canada and USA branches of the International Fiscal Association, May 23, 2014)
- “FATCA: Updates and Coordinating Regulations” (Co-Author) (Thomson Reuters - Derivatives Financial Products Report, May 2014)
- "New Guidance Regarding Ownership of Passive Foreign Investment Companies" (Co-Author,Journal of Taxation of Investments, Spring 2014)
- “Intergovernmental Tax Reporting, Information Gathering and Coordination” (Panelist, 3rd Joint Meeting of the Tax Section of the International Bar Association and the Chartered Institute of Taxation on Current International Tax Issues in Cross-Border Corporate Finance and Capital Markets, London, February 11, 2014)
- “Advanced FATCA and Recent Developments” (Panelist, Annual Meeting of the New York State Bar Association Tax Section, New York City, January 28, 2014)
