Hal Hicks is a partner in Skadden, Arps’ international tax practice and resident in the firm’s Washington, D.C. office. His practice focuses on a wide range of international tax issues for multinational corporations, partnerships and other entities involving both tax planning and tax controversy. Mr. Hicks has broad-based experience, particularly in the areas of international M&A, foreign tax credit, transfer pricing and subpart F.
Since coming to Skadden in early 2007, Mr. Hicks has represented clients in a wide range of transactions and other matters, including:
- Blackrock’s acquisition of Barclay’s asset management business;
- American Standard’s restructuring and split-off;
- Schering-Plough Corporation’s acquisition by Merck & Co., Inc.;
- Eli Lilly’s acquisition and post-acquisition restructuring of ImClone Systems; and
- James Hardie’s migration from the Netherlands to Ireland.
He also has represented numerous clients in internal restructurings and post-acquisition integration efforts, including Hewlett-Packard Company, General Electric, Wynn Resorts, Procter & Gamble Co., IBM, E. I. du Pont de Nemours and Company, The Coca-Cola Company, MetLife, Exxon Mobil Corporation and Liberty Mutual. Mr. Hicks also has represented numerous clients in audits, appeals and otherwise before the Internal Revenue Service and Department of the Treasury. For example, he has advised AstraZeneca International, Abercrombie & Fitch, MetLife, Federal Express, Hewlett-Packard and Wynn Resorts.
Mr. Hicks served as the international tax counsel at the Department of the Treasury from 2005-2007. In this position, he was the principal legal adviser to the secretary and the assistant secretary (tax policy) on all international tax matters. He oversaw the lawyers and economists working in the international tax area, including with respect to legislation, treasury regulations and other published guidance and treaties. Mr. Hicks led the U.S. delegation at the OECD and other international tax forums. Prior to his position at the Treasury, Mr. Hicks served as associate chief counsel (international) in the Office of Chief Counsel at the Internal Revenue Service (IRS) from 2003-2005. He is only the second person to hold both the top international tax positions at the Treasury and the Office of Chief Counsel. During his time as ACCI, Mr. Hicks supervised more than 120 international tax professionals, including those in the Advanced Pricing Agreement Program. His group was responsible for published guidance, TAMs, private rulings, closing agreements and APAs in all areas of international tax. Mr. Hicks also served as principal legal adviser on all international tax matters to IRS National Office, Field, Exam and Appeals.
Mr. Hicks’ tenure at the Treasury and the Office of Chief Counsel was particularly noted for the quality and quantity of published international tax guidance. This included extensive guidance in transfer pricing, international M&A, foreign tax credit, subpart F, DCL and section 987 areas. It also included substantial guidance under section 965 enacted as part of the American Jobs Creation Act. Mr. Hicks received both the Treasury Honor Award and the Chief Counsel Award for his government service.
Prior to his government service, Mr. Hicks had been in private practice for many years, representing clients in planning and controversy on both outbound and inbound matters, as well as on domestic matters.
Mr. Hicks was included in the Tax Directors Handbook 2009, The International Who’s Who of Corporate Tax Lawyers 2008-2009 and in the international tax section of The Legal 500 2007-2009.
LL.M. (Tax), New York University School of Law
J.D., University of Virginia School of Law
B.A., College of William and Mary
International Tax Counsel, Department of Treasury (2005-2007)
Associate Chief Counsel (International), Internal Revenue Service (2003-2005)
Member, Advisory Board, IRS/GW Conference
Member, Advisory Board, International Tax Journal
“The Long and Winding (GRA) Road — Final Gain Recognition Agreement Regulations,” International Tax Journal to be published September 2009) (with Dan McCall)
District of Columbia
U.S. Treasury Honor Award (2007); Chief Counsel Award (2005)