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France

Laurent Borey

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Partner

Mayer Brown

Paris

+33 1 53 53 43 43

lborey@mayerbrown.com

www.mayerbrown.com

Languages: French, English, Spanish

Bar admissions: Paris

Biography

Laurent Borey is one of France's leading tax lawyers on private equity matters (fund structuring and transaction) representing private equity sponsors.

He is singled out for his vast experience in the tax structuring of large, complex, cross-border M&A transactions and expertise in personal tax matters of top managers, tax audit and litigations.

Recent matter highlights

  • Advised the investment fund Charterhouse in the structuring of the acquisition of the insurance broker SIACI Saint Honoré

  • Advised the French Dutch laboratory Cooper-Vemedia on the structuring aspects of the € 158 million acquisition of 12 pharmaceuticals brands from Sanofi

  • Advised Altice NV on tax and structuring aspects of the IPO and NYSE Listing of Altice USA

  • Advised Eurazeo with regards to the tax structuring of its acquisition from Accor of 85 hotels in France and Europe

Practice areas

Restructuring, M&A, Corporate taxes, Audit defence, Tax consulting, Transfer pricing

Sector specialisations

Consumer goods and services, Energy, Financial services, Food and beverage, Healthcare, Industrials, Investment management, Media, Pharma and life sciences, Real estate, Tech and telecoms

Association memberships

Association des Anciens d'Arthur Andersen

Academic qualifications

Université de Dijon: DESS de Fiscalité

Université Paris II Panthéon-Assas: Maîtrise Droit des Affaires et Fiscalité

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Richard Foissac

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Partner

CMS Francis Lefebvre Avocats

Neuilly-sur-Seine

+33 1 47 38 40 25

richard.foissac@cms-fl.com

cms.law/fr/FRA/

Languages: French, English

Bar admissions: 12th October 1990

Biography

Richard joined CMS Francis Lefebvre Avocats in 1988 and was co-opted as an equity partner in 1998. He chaired the firm's advisory board from 2009 to 2012. He is an expert in direct taxes, and mainly manages mainly cases in the following subject matters: corporation tax for listed and non-listed companies (French and international); personal income tax; real estate and finance taxation, for listed and non-listed French and international companies; and tax systems for semi-public companies and local authorities.

Richard is also specialised in tax litigation and in tax penal claims. In this context, he and his team have spent many years assisting several groups, companies and their key individuals, in tax dawn raid procedures (section L 16B of the French tax code) and in tax criminal procedures; as a tax litigation lawyer, he also regularly pleads (including in criminal tax).

Richard is well known by the French tax administration as an expert of those matters, and regularly publishes different articles on these matters in specialised publications.

He is a lecturer at the Universities of Paris I (Panthéon-Sorbonne), Sophia-Antipolis and Montpellier. He is also a member of the IACF and of the ACE.

Practice areas

Direct taxes; corporation tax for listed and non-listed companies; personal income tax; real estate and finance taxation; tax litigation; tax penal claims.

Association memberships

Richard is a member of the IACF and of the ACE.

Academic qualifications

Postgraduate degree in business law from the University of Montpellier (DJCE)

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Benjamin Homo

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Partner

Mayer Brown

Paris

+33(0)153534343

bhomo@mayerbrown.com

www.mayerbrown.com/people/benjamin-homo/

Languages: French, English

Bar admissions: Paris, France

Biography

Benjamin Homo has extensive experience representing taxpayers at all stages of tax disputes, from the assistance during the audit process to final litigation in front of French administrative and civil courts, including intermediary administrative phases and settlement negotiations.

Recent matter highlights

  • Assistance to a subsidiary of a French listed company against the re-characterization of debt into equity (300m euro reassessment, eventually fully waived by the authorities)

  • Assistance to various French management teams in respect of the re-characterization into employment income of the gains derived from their equity investment in LBO Transactions ("Management Packages")

Practice areas

Transactions, Corporate taxes, Audit defence, Litigation, Tax consulting

Sector specialisations

Consumer goods and services, Financial services, Healthcare, Investment management, Real estate

Academic qualifications

  • HEC Business School – Master in Management – Grande Ecole Degree – 1996

  • Université Paris II Panthéon-Assas – Diplôme d'Etudes Supérieures Spécialisées (DESS) in International Tax – 1996

  • Paris Bar – 1999

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Christopher Lalloz

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Partner

Mayer Brown

Paris

+33 (0)1 53 53 51 84

clalloz@mayerbrown.com

www.mayerbrown.com

Languages: French, English

Bar admissions: Paris

Biography

Building on extensive experience gained on successful tax audits and litigations for a wide range of French and foreign clients, Christopher focuses his activity on structuring organizations, transactions and investment schemes with measured risk-taking and defending his clients' positions before the French tax authorities or the French courts.

Recent matter highlights

  • Tax audit of a large multinational distribution group re an internal reorganization. Initial tax reassessment: c. €250 million. Final tax reassessment (after two years of negotiation): c. €15 million

  • Tax audit of a wealthy entrepreneur re the sale of his group. Initial tax reassessment: circa €6 million. Reassessment eventually waived by the authorities

  • Tax audit of a listed French company by a foreign administration (Middle East) re: transfer pricing

Practice areas

Corporate taxes, Audit support, Litigation, Tax consulting, International tax advisory

Sector specialisations

Consumer goods and services, Industrials, Investment management

Academic qualifications

1999: Certificate of specialisation in tax (with honours), University of Montpellier I.

1999: DESS – DJCE (specialized corporate and tax counsel qualification (with honours), post-graduate Degree in corporate and tax law (DESS), University of Nancy II.

2001: ICN Business School (with honours), University of Nancy II.

2002: Admitted to the French Bar.

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Alain Frenkel

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Lawyer – Partner

Frenkel&Associés

Paris

+33 (0)1 42258888

a.frenkel@taxlex.com

www.frenkel-associes.fr

Languages: French, English

Biography

Alain Frenkel specialises in tax litigation, a field in which he has over 30 years of experience and is considered as one of the best. After having co-founded the law firm Veil Jourde, he created Frenkel&Associés in 2003. His partner Marc Pelletier is a leading specialist in constitutional law. They lead the main French tax litigation conferences.

Recent matter highlights

  • Layher, Constitutional Court, 2016: declaration of unconstitutionality of the provisions limiting exemption from the 3% additional corporate tax contribution on dividends to fiscally consolidated groups.

  • The Firm also assisted Jeff de Bruges in claiming that the contribution was unconstitutional given the reverse discrimination introduced.

  • Layher, Conseil d'Etat, 2017: annulation of the postponement of the repeal of these provisions until 01.01.2017 in the light of arguments based on the ECHR.

Practice areas

Pre-litigation, Litigation, Tax consulting, International tax advisory, Lobbying

Association memberships

Alain Frenkel is a member of International Fiscal Association (IFA) and Vice-President of IACF (Institut des avocats conseils fiscaux – Institute of Tax Lawyers).

Academic qualifications

Alain Frenkel has Masters in public and private law, a Ph.D. in law, is a Laureate of the Paris II University, and is also a graduate of Sciences-Po Paris.

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Vincent Agulhon

Darrois Villey

Stéphane Austry

CMS Bureau Francis Lefebvre

Gauthier Blanluet

Sullivan & Cromwell

Delphine Bocquet

PwC

Eric Bonneaud

PwC

Laurent Borey

Mayer Brown

Bernard Boutémy

Jeausserand Audouard

Ariane Calloud

Baker McKenzie

Manuel Castro

Cabinet Castro & Associé

Michel Combe

PwC

Sabina Comis

Dechert

Jean-Charles David

Ateleia

Nicolas de Boynes

Sullivan & Cromwell

Philippe Derouin

Philippe Derouin

Gilles Entraygues

Cleary Gottlieb Steen & Hamilton

Pierre Escaut

PwC

Richard Foissac

CMS Bureau Francis Lefebvre

Alain Frenkel

Frenkel & Associés

Bruno Gibert

CMS Bureau Francis Lefebvre

Antoine Glaize

Arsene Taxand

Michel Guichard

Deloitte

Sandra Hazan

Dentons

Benjamin Homo

Mayer Brown

Audrey Laure Illouz-Chetrit

Fidal

Christopher Lalloz

Mayer Brown

Eric Lesprit

Deloitte

Philippe Lion

Baker McKenzie

Laurence Mazevet

Fidal

Eric Meier

Baker McKenzie

Charles Ménard

EY

Gianmarco Monsellato

Deloitte

Eve Obadia

Wagener & Associés

Marc Pelletier

Frenkel & Associés

Elisabeth Rivière

PwC

Guillaume Rubechi

Valoris Avocats

Pascal Seguin

Deloitte

Mathieu Selva-Roudon

LPA Law

Régis Torlet

Baker McKenzie

Jérôme Turot

Cabinet Turot

Cyril Valentin

Freshfields Bruckhaus Deringer

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