David Hariton is a leading expert on the U.S. tax treatment of financial instruments and transactions, corporate restructurings, leveraged finance, insolvency and cross-border investments. He advises many leading financial institutions, including Barclays, Citadel, Citigroup, Credit Suisse, Goldman Sachs, JP Morgan Chase, PayPal, Inc. and Société Générale. In that capacity, he has been involved in the initial development of many new financial instruments, including trust preferred securities in the 1990s, debt-equity units in the 2000s, and a variety of other exchangeable and convertible instruments. He routinely represents clients in connection with major financial transactions and helps multinational corporations organize their operations in ways that are more efficient for U.S. tax purposes. He has acted for more than 20 years as principal outside counsel to the securities industry and has in that capacity written a large number of reports and letters on industry-wide issues to Treasury and the IRS, and has led various lobbying initiatives. Mr. Hariton has also advised numerous clients in respect of controversies at the audit and appellate levels dealing with financial instruments and transactions and has developed arguments and insights that have persuaded the IRS not to propose adjustments.
Mr. Hariton chaired the Tax Section of the New York State Bar Association in 2005 and is a member of the Tax Forum and the Tax Club. He also frequently speaks before the IRS and other governmental entities and for such private organizations as the University of Chicago Law School, NYU Law School, Columbia Law School, the University of Virginia Law School, the Wall Street Tax Association, the Practicising Law Institute, the American Bar Association and the New York State Bar Association.
Mr. Hariton has published more than 60 articles and reports on the tax treatment of financial instruments and transactions, many of which are frequently cited in the tax literature by professors and practitioners. Selected articles include:
Mr. Hariton is consistently ranked by Chambers and other industry publications as among the top few U.S. tax lawyers dealing with financial transactions and instruments. Summaries in their publications generally cite his exceptional knowledge, insight and judgment in respect of complex transactions and the rules that apply to them.
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