Pamela M. Capps

Represented Wear Me Apparel d/b/a Kids Headquarters in an acquisition of assets by Li & Fung Ltd., subsidiary of LF USA.

Represented Rocawear in its sale to Iconix Brand Group Inc.

Represented New Valley in connection with its joint venture investment with Property Markets Group and Kamran Hakim in the development of Queens Plaza South.

Represented The Peebles Corp. in connection with a joint venture in the purchase and redevelopment of 346 Broadway.

Advised Leading Pharma LLC on tax and structuring issues in its acquisition of substantially all of the assets of Excellium Pharmaceutical Inc., as well as in connection with a private equity offering by Leading Pharma’s parent company.

Represented Millennium Partners in the sale of Sports Club/LA and Reebok Sports Club/NY.

Represented AIG, Allied World Assurance and other issuers of M&A representation and warranty policies.

Represented several clients in challenging New York State's and New York City's use of its discretionary authority.

Represented a foreign bank in tax litigation with New York City involving the application of certain treaty provisions to the New York City bank tax, and whether income from certain loan participations of the bank constitutes effectively connected income in the United States.

Represented a financial services organization in a New York City litigation involving the ability of a partnership to claim deductions under Internal Revenue Code Section 754 for unincorporated business tax purposes.

Advised a leading provider of dark fiber and advanced network services in connection with the application of Internal Revenue Code Section 382 to the calculation of the taxpayer’s alternative net operating loss deductions.

Represented a large fashion company in connection with an IRS audit, including issues related to transfer pricing.

Represent a high-net-worth individual in connection with an IRS audit relating to the sale of an interest in a multibillion dollar hedge fund involving issues arising from different taxable regimes in the U.S. and the U.K..