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    Home /  Lawyers /  S. Eric Wang

    S. Eric Wang

    Partner

    S. Eric Wang Headshot Photo Portrait backdrop

    New York

    +1-212-558-3328

    London

    +44-20-7959-8411

    |

    wangs@sullcrom.com

    Email vCard

    Eric Wang is a member of Sullivan & Cromwell’s Tax Group and concentrates on U.S. tax matters. A partner since 2010, Mr. Wang advises on a broad range of planning and transactional matters for both U.S. and non-U.S. clients. He has advised extensively on cross-border acquisitions and joint ventures, including structuring a number of investments made by private equity and real estate funds worldwide. He also advises on U.S. tax issues relating to tax-sensitive financing structures and novel financial instruments, as well as debt restructurings. In addition, Mr. Wang has represented clients with respect to IRS audits and investigations. He frequently speaks at industry events on a wide range of domestic and international tax matters. Clients he has advised recently include AB In-Bev, Ally Financial, BHP, BP, Chevron, Enbridge, Goldman Sachs, Haleon, and Rhône Capital.

    Publications

    • “Tax Reform: Implications for Multinational Businesses, M&A, and Private Equity” in Practical Law The Journal (March 2018) (co-author)
    • “Expert Q&A on the OECD’s BEPS Project” in Practical Law The Journal (March 2016) (co-author)
    • “BEPS: The US Perspective” in Tax Journal (July 2014)
    • “US transfer pricing audit roadmap can help taxpayers” in International Tax Review (March 2014)
    • “Debt-equity litigation returns to US courts” in British Tax Review (January 2013)
    • “Final Section 482 Cost Sharing Regulations: A renewed Commitment to the Income Method” in Bloomberg/BNA’s Tax Management Transfer Pricing Report (January 2012)
    Read More

    Spotlight

    S&C Advises American International Group on $1.25 Billion Registered Notes Offering

    Read More

    S&C Advises ING Groep on $3.5 Billion SEC-Registered Notes Offering

    Read More

    S&C Advises Underwriters in Equitable Holdings’ $500 Million Debt Offering

    Read More

    S&C Advises BHP on $3 Billion SEC-Registered Notes Offering

    Read More

    S&C Advises Adient Global Holdings in Rule 144A/Reg S Notes Offering

    Read More
    • Experience
    • Rankings and Recognitions
    • News
    • Credentials
    • Related Practices
    Experience

    Experience

    M&A

    • Ally Financial in the sale of Ally Lending to Synchrony
    • Bakkt in the divestiture of its Trust custody business to Intercontinental Exchange
    • Castor Maritime in its spin-off of Toro Corp., including its tankers’ business, into a standalone, publicly traded company
    • Chevron U.S.A. in its acquisition of a majority interest in ACES Delta, which is developing a renewable energy hub to convert, store and deliver green hydrogen to the Western U.S.
    • Discover Financial Services in its $35.3 billion pending merger with Capital One Financial Corporation

    • Enbridge in its acquisition of The East Ohio Gas Company and pending acquisitions of Questar Gas Company and its related Wexpro companies and Public Service Company of North Carolina from Dominion Energy for $14 billion
    • Haleon Group in its demerger from the GSK Group, making Haleon the world’s biggest stand-alone consumer health company
    • HomeStreet, the holding company of HomeStreet Bank, in HomeStreet Bank’s pending merger with Mechanics Bank
    • J.C. Flowers in its $125 million investment in Capital Funding Bancorp
    • KeyCorp in the 14.9% investment by Scotiabank
    • PacWest Bancorp in its all-stock merger with Banc of California
    • Rhône Capital and Fogo de Chão in connection with Fogo de Chão’s $1.1 billion acquisition by Bain Capital Private Equity
    • Wells Fargo in its sale of Norwest Equity Partners and a related portfolio of private equity fund interests

    Capital Markets

    • Adient in its $795 million aggregate offering of senior notes
    • Ally Financial in its $1 billion aggregate offering of senior notes
    • $1.25 billion SEC-registered notes offering
    • American International Group in its $1.5 billion cash tender offer to purchase certain series of its outstanding debt securities
    • Bank of Montreal in its SEC-registered $1.05 billion aggregate offering of senior notes
    • BHP Group Limited in the $3.0 billion SEC-registered offering of fixed-rate guaranteed senior notes by BHP Billiton
    • BP in its $1.25 billion SEC-registered offering of guaranteed notes
    • CRH plc in its concurrent SEC-registered $1.25 billion and $500 million aggregate offerings of senior guaranteed notes.
    • ING Groep N.V. in its $3.5 billion SEC-registered offering of senior notes

    Tax Controversy & Other Advisory Work

    • Confidential clients in tax controversy matters, including responding to IRS audits and third party information requests
    • Confidential corporate clients in relation to tax planning and other advice (including cross-border planning)
    • U.S. high net worth individuals and/or their family offices in relation to the application of cross-border tax rules to complex arrangements
    Read More
    Rankings and Recognitions

    Rankings and Recognitions

    • Law360 MVP in Tax (2020)
    • The Legal 500 United States (2014, 2015, 2016, 2017, 2018)
    • “Next Generation Lawyer” The Legal 500 United States (2017, 2018)
    • “Transatlantic Lawyer of the Year: Tax” by The American Lawyer’s Transatlantic Legal Awards (2016)
    • Chambers Global (2013, 2014, 2015)
    • Chambers USA (2022, 2023, 2024)
    • The Legal 500 United Kingdom (2014, 2015, 2016, 2017)
    Read More
    News

    News

    • S&C Obtains Appellate Reversal for Sumitomo Entities in Tax Dispute Over International Mining Deal

      May 20, 2025
    • S&C Advises American International Group on $1.25 Billion Registered Notes Offering

      May 14, 2025
    • S&C Advises Underwriters in Equitable Holdings’ $500 Million Debt Offering

      April 8, 2025
    • S&C Advises ING Groep on $3.5 Billion SEC-Registered Notes Offering

      April 8, 2025
    • S&C Advises BHP on $3 Billion SEC-Registered Notes Offering

      March 3, 2025
    • S&C Advises Adient Global Holdings in Rule 144A/Reg S Notes Offering

      February 12, 2025
    Read More
    Read More
    Credentials

    Credentials

    Education

    • Harvard Law School, J.D., 2001
    • Harvard University, A.B., 1998

    Bar Admissions

    • New York
    Read More
    Related Practices

    Related Practices

    • Tax
    • Environmental, Social and Governance (ESG)
    • Europe
    • Investment Management
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