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S. Eric Wang


S. Eric Wang

New York +1-212-558-3328 +1-212-558-3328 +1-212-558-3588 +1-212-558-3588
London +44-20-7959-8900 +44-20-7959-8900 +44-20-7959-8950 +44-20-7959-8950
[email protected]

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. Mr. Wang has also advised clients on their response to and compliance with the Foreign Account Tax Compliance Act (“FATCA”) since its introduction in late 2009. He frequently speaks at industry events on a wide range of domestic and international tax matters, including Practising Law Institute and International Fiscal Association. Clients he has advised recently include AB In-Bev, Barclays, BHP, Enbridge, Goldman Sachs, Rhône Capital and Total.

  • “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)


  • American International Group, Inc. on its sale of United Guaranty Corporation to Arch Capital Group Ltd.
  • BP in its agreement with Bridas Corporation to form a new integrated energy company, Pan American Energy Group, by combining their interests in the oil and gas producer Pan American Energy  and the refiner and marketer Axion Energy
  • Concho Resources in its $9.5 billion acquisition of RSP Permian
  • Goldman Sachs in the sale and purchase agreement, along with its affiliates, for 64% of the shares in Rothesay Holdco UK Limited; on its investment in the Hastings Insurance Group; on its £2 billion joint venture with the Wellcome Trust and Greystar to form a new student accommodation company; and its acquisition of Continental Bakeries from NPM Capital
  • Rhône Capital in connection with its affiliated investment entities’ $560 million all cash acquisition of Fogo de Chão; in its acquisition of Zodiac Pool for $1.2 billion; its 45% and 29% increases in ownership of Garda World Security Corporation; and on its acquisition of GK Holdings, Inc. from MidOcean Partners III, L.P., affiliates thereof, and other equity holders and option holders of GK Holdings, as well as the related financing
  • Royal Philips in its $2 billion acquisition of The Spectranetics Corporation; and in its in its acquisition of Respiratory Technologies
  • Tinicum Incorporated in connection with its affiliated investment funds' acquisition of Astrodyne

Capital Markets
  • the underwriters in Alibaba Group Holding Limited’s SEC-registered initial public offering of $25.03 billion. This is the largest ever U.S. IPO, the largest ever IPO by a technology company, as well as the largest IPO ever globally
  • Anheuser-Busch InBev SA/NV in its pricing of $46 billion of senior, unsecured notes via an SEC-registered public offering
  • Barclays on its numerous issuances of contingent capital subordinated notes
  • BP Capital Markets plc/ BP p.l.c. in its offers to exchange up to $10.6 billion aggregate principal amount of new SEC-registered notes for 12 series of U.S. dollar-denominated debt securities and in its $2.0 billion SEC-registered note offering and listed on New York Stock Exchange
  • ING Groep N.V. on $2.25 billion of contingent convertible capital securities, the first CRD IV-compliant AT1 security issued by a Dutch financial institution
  • the underwriters on a number of high-yield notes offerings by Jaguar Land Rover
  • Royal Philips on the IPO of Philips Lighting B.V.
Other Advisory Work
  • Trustees in relation to U.S. federal income tax risks, inherent in situations where beneficiaries are U.S. citizens or residents
  • U.S. high net worth individuals and/or their family offices in relation to the application of various tax compliance rules to complex arrangements
  • Confidential clients in relation to tax reform related planning and other advice (including cross-border planning)
  • several U.S. and non-U.S. financial institutions with respect to FATCA compliance and due diligence, reporting and withholding rules that will be applicable to “foreign financial institutions”
  • Marcobre S.A.C. (Peru) and the Project, whose sponsors are Minsur and Alxar (Copec’s mining subsidiary), on tax matters relating to the $900 million project financing for the development of the $1.77 billion Mina Justa copper project


  • 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)
  • The Legal 500 United Kingdom (2014, 2015, 2016, 2017)