Nicholas J. DeNovio

Washington, D.C.
  • 555 Eleventh Street, NW
  • Suite 1000
  • Washington, D.C. 20004-1304
  • USA
Profile Experience

Nicholas DeNovio, Global Chair of Latham & Watkins’ International Tax Practice, is a partner in the Washington, D.C. office and member of the Audit Committee and Strategic Client Committee. Throughout his career, Mr. DeNovio has represented large US and non-US based multinational corporations on complex cross-border transactions involving mergers and acquisitions, spin-offs, financings, and group structuring. He has represented a number of the world's leading corporations on multi-billion dollar transactions covering jurisdictions around Europe, Asia, and the Americas.

Mr. DeNovio began his career in private practice in New York and became a partner at a global law firm. Prior to joining Latham, Mr. DeNovio served as Deputy Chief Counsel (Technical) at the IRS Office of Chief Counsel where he:

  • Handled overall management and substantive tax aspects of the regulatory guidance process of the IRS National Office and taxpayer-specific guidance
  • Supervised the IRS regulatory guidance program
  • Led the regulatory guidance required after the enactment of the American Jobs Creation Act
  • Directed the issuance of dozens of other major regulatory initiatives on various tax provisions
  • Served as the principal technical legal resource for the operating divisions of the IRS

Mr. DeNovio is consistently ranked by The Legal 500 US, Chambers USA, and Super Lawyers as one of the leading tax lawyers in the District of Columbia. In addition, The Legal 500 US and Chambers Global regularly recognize him for his international tax work.

He is a member of the board for the George Washington University/IRS International Tax Program and served as Chair of the University of Chicago Federal Tax Conference from 2012 – 2014.

Thought Leadership

Mr. DeNovio is a renowned speaker and writer for organizations such as Tax Executives Institute (TEI), Practicing Law Institute (PLI), International Fiscal Association (IFA), National Foreign Trade Council (NFTC), and various bar associations. He has authored and spoken on an array of tax-related topics including:

  • Co-author, “Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction,” Latham & Watkins Client Alert (August 2018)
  • Co-author, “Cross-Border M&A: Putting the Recently Finalized US Inversion Regulations into Context Following US Tax Reform,” Latham & Watkins Client Alert (July 2018)
  • Co-author, “IRS Launches New Compliance Campaigns on Repatriation of Foreign Earnings and Virtual Currency,” Latham & Watkins Client Alert (July 2018)
  • Co-author, “New Guidance Issued for Transition Tax on Deferred Foreign Earnings,” Latham & Watkins Client Alert (April 2018)
  • Co-author, “Multinational Financial Groups After the U.S. Tax Reform: Selected Inbound and Outbound Issues,” Latham & Watkins Client Alert (April 2018)
  • Speaker, “Navigating Tax Reform: A Plain English Discussion of Financing, M&A Transaction, and Disclosure Issues,” Latham & Watkins Webcast (January 2018)
  • Co-author, “US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams,” Latham & Watkins Client Alert (January 2018)
  • Co-author, “Congress Passes Tax Reform Legislation, Implementation Imminent,” Latham & Watkins Client Alert (December 2017)  
  • Speaker, “US Tax Reform: Understanding the Proposals and Executing Transactions in the Face of Uncertainty,” Latham & Watkins Webcast (February 2017)
  • Co-author, “Treasury Issues Final and Temporary Regulations on Related-Party Debt Instruments,” Latham & Watkins Client Alert (October 2016)
  • Co-author, “IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be Broader,” Latham & Watkins Client Alert (September 2016)   
  • Co-author, “10 Steps to Mitigate EU State Aid Exposure on Tax Arrangements,” Latham & Watkins Client Alert (September 2016)
  • Co-author, “Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity,” Latham & Watkins Client Alert (April 2016)

Mr. DeNovio’s selected experience includes representation of:

  • Allergan in its US$40.5 billion sale of Global Generic Pharmaceuticals Business to Teva Pharmaceuticals
  • FMC Technologies, Inc. in its US$13 billion merger of equals with Technip, via the EU cross-border merger regime
  • Globe Specialty Metals in its US$3.1 billion merger of equals with Grupo FerroAtlantica to create a leading international silicon and specialty metals producer
  • Sorin in its US$2.7 billion mergers of equals with Cyberonics to create a new medical technology company
  • Actavis in its US$8.5 billion acquisition of Warner-Chilcott, an Ireland-based pharmaceutical company focusing on women’s healthcare
  • Actavis in its US$28 billion acquisition of Forest Laboratories, a specialty pharmaceutical company
  • Yahoo! in its acquisition of Maktoob, Ltd.
  • Avery Dennison, a leader in pressure-sensitive labeling materials, retail tag, ticketing and branding systems, and office products during its acquisition of DM Label Group, an Asian-based manufacturer
  • Mattel in its US$230 million acquisition of Radica Games Limited Bermuda, an electronic games manufacturer
  • Advanced Micro Devices, Inc. (AMD) in its US$5.4 billion acquisition of ATI Technologies Canada, a producer of microprocessors
  • Several major multinational corporations in internal whistleblower investigations involving global tax issues
  • Major companies in internal restructuring in pre and post transaction efforts, including: Autodesk, Electronic Arts, Owens Illinois, Citibank, General Electric, WR Grace, Omnicom Group, Inc., Jabil Corporation, Diageo plc, and Viasat
  • Numerous companies of similar stature on matters involving the IRS, at all levels of the IRS administrative process
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