David R. Hardy

David R. Hardy focuses his practice on corporate and international tax, particularly in the energy industry. He handles cross-border merger transactions, including public company stock acquisitions, joint ventures, project financings, cross-border security issuances, inbound and outbound securities, real estate and private equity partnerships.

David is a frequent speaker and author on various tax-related topics, and has been the principal author of several NYS Bar Tax Section reports. He has written on the base erosion and anti-abuse tax, the anti-double dip finance provisions, the anti-hybrid provisions of the US-Canada treaty, the non-recognition rules regarding the outbound transfers of intangible property, and the consistency principle in tax treaty interpretation.

• Developed and implemented a multi-billion dollar tax advantaged intragroup restructuring for a major publicly traded North American company*
• Structured a multi-billion dollar combination of two US groups of a public European company*
• Advised on a $400 million intragroup debt relief transaction with beneficial SRLY consequences*
• Structured a $7 billion cross-border acquisition of intangible and operating assets*

*Matter handled prior to joining the firm

• Who’s Who Legal, Corporate Tax – Advisory (International), 2020
• Super Lawyers, Tax, 2020

• International Tax Institute of New York, past president
• New York State Bar Tax Section, Executive Committee, member
• Tax Committee of the International Bar Association, past Chair
• Tax Committee of the ABA Infrastructure Committee, past Chair