David P Hariton

Tax; Commodities, Futures & Derivatives; Energy Transition

David Hariton is a leading expert on the U.S. tax treatment of financial instruments and transactions, corporate restructurings, leveraged finance, insolvency and cross-border investments. He advises many leading financial institutions, including Barclays, Citadel, Citigroup, Credit Suisse, Goldman Sachs, JP Morgan Chase, PayPal, Inc. and Société Générale. In that capacity, he has been involved in the initial development of many new financial instruments, including trust preferred securities in the 1990s, debt-equity units in the 2000s, and a variety of other exchangeable and convertible instruments. He routinely represents clients in connection with major financial transactions and helps multinational corporations organize their operations in ways that are more efficient for U.S. tax purposes. He has acted for more than 20 years as principal outside counsel to the securities industry and has in that capacity written a large number of reports and letters on industry-wide issues to Treasury and the IRS, and has led various lobbying initiatives. Mr. Hariton has also advised numerous clients in respect of controversies at the audit and appellate levels dealing with financial instruments and transactions and has developed arguments and insights that have persuaded the IRS not to propose adjustments.

ABA (Co-Chairman, Subcommittee on Hybrid Debt Instruments, Tax Section); NYSBA (Secretary, Tax Section).