Cravath’s New York Office Moves to Two Manhattan West
Andrew T. Davis focuses his practice on the tax aspects of mergers and acquisitions, including spin‑off and private equity transactions, as well as securities offerings and banking transactions.
Mr. Davis’s notable transactions include representing:
Mr. Davis was named a “Rising Star” by Law360 in 2022, recognizing him as one of five outstanding tax lawyers in the nation under the age of 40, and has been named to the Lawdragon 500 X – The Next Generation list. He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is a member of Corporate Tax Committee of the Tax Section of the American Bar Association and frequently speaks on important developments in tax law. He recently participated in a webinar entitled “CAMT and M&A Transactions: Challenges, Issues and (lots of) Questions,” which was hosted by the D.C. Bar as a part of its “Corporate Tax” webinar series.
Mr. Davis is from Montclair, New Jersey. He received an A.B. summa cum laude from Princeton University in 2010, where he was elected to Phi Beta Kappa, a J.D. from Stanford Law School in 2014, where he was an Articles Editor of the Journal of Law, Business & Finance, and an LL.M. from New York University School of Law in 2020.
Mr. Davis joined Cravath in 2014. Following a one‑year clerkship with Hon. Guido Calabresi of the U.S. Court of Appeals for the Second Circuit, he returned to the Firm in 2016 and was elected a partner in 2021.
Mr. Davis’s notable transactions include representing:
Mr. Davis was named a “Rising Star” by Law360 in 2022, recognizing him as one of five outstanding tax lawyers in the nation under the age of 40, and has been named to the Lawdragon 500 X – The Next Generation list. He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is a member of Corporate Tax Committee of the Tax Section of the American Bar Association and frequently speaks on important developments in tax law. He recently participated in a webinar entitled “CAMT and M&A Transactions: Challenges, Issues and (lots of) Questions,” which was hosted by the D.C. Bar as a part of its “Corporate Tax” webinar series.
Mr. Davis is from Montclair, New Jersey. He received an A.B. summa cum laude from Princeton University in 2010, where he was elected to Phi Beta Kappa, a J.D. from Stanford Law School in 2014, where he was an Articles Editor of the Journal of Law, Business & Finance, and an LL.M. from New York University School of Law in 2020.
Mr. Davis joined Cravath in 2014. Following a one‑year clerkship with Hon. Guido Calabresi of the U.S. Court of Appeals for the Second Circuit, he returned to the Firm in 2016 and was elected a partner in 2021.
American Bar Association
New York State Bar Association
Law360
Lawdragon
The Legal 500 US
Deals & Cases
June 17, 2024
Cravath represented the initial purchasers in connection with the $1.225 billion 144A/Reg. S high‑yield senior secured notes offering of CHS/Community Health Systems, Inc. CHS/Community Health Systems, Inc., together with its parent company, Community Health Systems, Inc., is one of the nation’s largest healthcare companies. The transaction closed on June 5, 2024.
Deals & Cases
June 14, 2024
Cravath represented the underwriter in connection with the $391.2 million registered secondary offering of class A common stock of Hess Midstream LP, a fee‑based, growth‑oriented, limited partnership formed by Hess Midstream GP LP and Hess Infrastructure Partners GP LLC to own, operate, develop and acquire a diverse set of midstream assets and provide fee‑based services to Hess Corporation and third-party customers. The transaction closed on May 31, 2024.
Deals & Cases
June 05, 2024
Cravath represented the administrative agent, joint lead arranger and joint bookrunner in connection with $1.5 billion of credit facilities made available to Monster Beverage Corporation, a leading developer and distributer of energy drink beverages. The facilities consisted of a $750 million revolving credit facility and a $750 million term loan facility. The transaction closed on May 22, 2024.
Deals & Cases
June 04, 2024
Cravath represented the initial purchasers in connection with the $600 million 144A/Reg. S high‑yield senior notes offering of Hess Midstream Operations LP, a fee‑based, growth‑oriented, limited partnership that owns, operates, develops and acquires a diverse set of midstream assets and provides fee‑based services to Hess and third‑party customers. The transaction closed on May 16, 2024.
Deals & Cases
June 03, 2024
Cravath represented the underwriters in connection with the $1.65 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on May 20, 2024.
Activities & Publications
May 08, 2024
On May 6, 2024, Cravath prepared a memo for its clients entitled “IRS and Treasury Update Guidelines for Spin‑Off Private Letter Rulings, Narrowing IRS Practice.” The memo examines the Internal Revenue Service’s recently released Rev. Proc. 2024‑24 and Notice 2024‑38, which provide updated guidelines for taxpayers requesting private letter rulings from the IRS for tax‑free spin‑off and split‑off transactions under Section 355. The memo outlines the key changes in the IRS’s ruling practice for spin-offs, which reflect a significant narrowing of the current ruling practice, that are related to debt‑for‑equity exchange structuring, the use of proceeds in “boot purges,” contingent liabilities and retentions of Spinco stock.
Activities & Publications
February 13, 2024
On January 20, 2024, Cravath partner Andrew T. Davis participated in the American Bar Association’s Tax Section 2024 Midyear Meeting, which was held from January 18‑20 in San Francisco, CA. The event convened leading tax attorneys and government officials to discuss the latest federal, state and local tax policies. Andrew spoke on a panel entitled “Current Developments in Corporate Taxation,” which reviewed legislative and administrative developments in corporate taxation, including new regulatory and other guidance for the Corporate Alternative Minimum Tax and the Excise Tax as well as changes to the private letter ruling program.
Activities & Publications
January 29, 2024
On January 22, 2024, Cravath partner Andrew T. Davis spoke at the USC Gould School of Law 2024 Tax Institute, which was held from January 22‑24, 2024, in Los Angeles, CA. Andrew spoke on a panel entitled “Recent Developments in Corporate Taxation Planning,” which reviewed anticipated Treasury and Internal Revenue Service guidance; Inflation Reduction Act guidance about the corporate book minimum tax and the stock buyback excise tax; IRS internal memos regarding intercompany transactions and partnership basis adjustments; recent interesting court cases; and challenges to the validity of legislation and Treasury guidance.
Activities & Publications
November 14, 2023
Cravath partner Andrew T. Davis participated in the 82nd Institute on Federal Taxation, which was hosted by the New York University School of Professional Studies from November 12‑17, 2023, in Berkeley, CA and hosted leading professionals to discuss the latest trends and developments in federal tax matters. Andrew spoke on a panel entitled “S Corporations - Not So Simple In Practice,” which examined the tax‑related challenges and opportunities encountered in M&A transactions involving S corporations.
Activities & Publications
July 05, 2023
On June 30, 2023, Cravath partner Andrew T. Davis was featured in Bloomberg Tax’s “Spotlight” series, which “highlights the careers and lives of tax professionals around the world.” In an accompanying Q&A, Andrew explained his focus on the tax aspects of M&A transactions, spoke to his educational background including how his research in Russian literature and applied mathematics informs his tax practice, and noted the impact of recent tax policy changes on corporate clients. Asked to contemplate the best tax or financial advice that anyone ever gave him, Andrew reflected on advice from his uncle: “My uncle, an oncologist, once described the three A’s of what it takes to be a successful young doctor: availability, affability, and ability, in that order. I think that advice equally applies to young tax practitioners—more than anything else, we should be a steady source of advice and support in working through complex, and sometimes anxiety-inducing, tax questions.”
Andrew T. Davis focuses his practice on the tax aspects of mergers and acquisitions, including spin‑off and private equity transactions, as well as securities offerings and banking transactions.
Mr. Davis’s notable transactions include representing:
Mr. Davis was named a “Rising Star” by Law360 in 2022, recognizing him as one of five outstanding tax lawyers in the nation under the age of 40, and has been named to the Lawdragon 500 X – The Next Generation list. He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is a member of Corporate Tax Committee of the Tax Section of the American Bar Association and frequently speaks on important developments in tax law. He recently participated in a webinar entitled “CAMT and M&A Transactions: Challenges, Issues and (lots of) Questions,” which was hosted by the D.C. Bar as a part of its “Corporate Tax” webinar series.
Mr. Davis is from Montclair, New Jersey. He received an A.B. summa cum laude from Princeton University in 2010, where he was elected to Phi Beta Kappa, a J.D. from Stanford Law School in 2014, where he was an Articles Editor of the Journal of Law, Business & Finance, and an LL.M. from New York University School of Law in 2020.
Mr. Davis joined Cravath in 2014. Following a one‑year clerkship with Hon. Guido Calabresi of the U.S. Court of Appeals for the Second Circuit, he returned to the Firm in 2016 and was elected a partner in 2021.
Mr. Davis’s notable transactions include representing:
Mr. Davis was named a “Rising Star” by Law360 in 2022, recognizing him as one of five outstanding tax lawyers in the nation under the age of 40, and has been named to the Lawdragon 500 X – The Next Generation list. He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is a member of Corporate Tax Committee of the Tax Section of the American Bar Association and frequently speaks on important developments in tax law. He recently participated in a webinar entitled “CAMT and M&A Transactions: Challenges, Issues and (lots of) Questions,” which was hosted by the D.C. Bar as a part of its “Corporate Tax” webinar series.
Mr. Davis is from Montclair, New Jersey. He received an A.B. summa cum laude from Princeton University in 2010, where he was elected to Phi Beta Kappa, a J.D. from Stanford Law School in 2014, where he was an Articles Editor of the Journal of Law, Business & Finance, and an LL.M. from New York University School of Law in 2020.
Mr. Davis joined Cravath in 2014. Following a one‑year clerkship with Hon. Guido Calabresi of the U.S. Court of Appeals for the Second Circuit, he returned to the Firm in 2016 and was elected a partner in 2021.
American Bar Association
New York State Bar Association
Law360
Lawdragon
The Legal 500 US
Deals & Cases
June 17, 2024
Cravath represented the initial purchasers in connection with the $1.225 billion 144A/Reg. S high‑yield senior secured notes offering of CHS/Community Health Systems, Inc. CHS/Community Health Systems, Inc., together with its parent company, Community Health Systems, Inc., is one of the nation’s largest healthcare companies. The transaction closed on June 5, 2024.
Deals & Cases
June 14, 2024
Cravath represented the underwriter in connection with the $391.2 million registered secondary offering of class A common stock of Hess Midstream LP, a fee‑based, growth‑oriented, limited partnership formed by Hess Midstream GP LP and Hess Infrastructure Partners GP LLC to own, operate, develop and acquire a diverse set of midstream assets and provide fee‑based services to Hess Corporation and third-party customers. The transaction closed on May 31, 2024.
Deals & Cases
June 05, 2024
Cravath represented the administrative agent, joint lead arranger and joint bookrunner in connection with $1.5 billion of credit facilities made available to Monster Beverage Corporation, a leading developer and distributer of energy drink beverages. The facilities consisted of a $750 million revolving credit facility and a $750 million term loan facility. The transaction closed on May 22, 2024.
Deals & Cases
June 04, 2024
Cravath represented the initial purchasers in connection with the $600 million 144A/Reg. S high‑yield senior notes offering of Hess Midstream Operations LP, a fee‑based, growth‑oriented, limited partnership that owns, operates, develops and acquires a diverse set of midstream assets and provides fee‑based services to Hess and third‑party customers. The transaction closed on May 16, 2024.
Deals & Cases
June 03, 2024
Cravath represented the underwriters in connection with the $1.65 billion registered senior notes offering of MPLX LP, a master limited partnership formed by Marathon Petroleum Corporation. MPLX LP owns, operates, develops and acquires pipelines and other midstream assets related to the transportation and storage of crude oil, refined products and other hydrocarbon-based products. The transaction closed on May 20, 2024.
Activities & Publications
May 08, 2024
On May 6, 2024, Cravath prepared a memo for its clients entitled “IRS and Treasury Update Guidelines for Spin‑Off Private Letter Rulings, Narrowing IRS Practice.” The memo examines the Internal Revenue Service’s recently released Rev. Proc. 2024‑24 and Notice 2024‑38, which provide updated guidelines for taxpayers requesting private letter rulings from the IRS for tax‑free spin‑off and split‑off transactions under Section 355. The memo outlines the key changes in the IRS’s ruling practice for spin-offs, which reflect a significant narrowing of the current ruling practice, that are related to debt‑for‑equity exchange structuring, the use of proceeds in “boot purges,” contingent liabilities and retentions of Spinco stock.
Activities & Publications
February 13, 2024
On January 20, 2024, Cravath partner Andrew T. Davis participated in the American Bar Association’s Tax Section 2024 Midyear Meeting, which was held from January 18‑20 in San Francisco, CA. The event convened leading tax attorneys and government officials to discuss the latest federal, state and local tax policies. Andrew spoke on a panel entitled “Current Developments in Corporate Taxation,” which reviewed legislative and administrative developments in corporate taxation, including new regulatory and other guidance for the Corporate Alternative Minimum Tax and the Excise Tax as well as changes to the private letter ruling program.
Activities & Publications
January 29, 2024
On January 22, 2024, Cravath partner Andrew T. Davis spoke at the USC Gould School of Law 2024 Tax Institute, which was held from January 22‑24, 2024, in Los Angeles, CA. Andrew spoke on a panel entitled “Recent Developments in Corporate Taxation Planning,” which reviewed anticipated Treasury and Internal Revenue Service guidance; Inflation Reduction Act guidance about the corporate book minimum tax and the stock buyback excise tax; IRS internal memos regarding intercompany transactions and partnership basis adjustments; recent interesting court cases; and challenges to the validity of legislation and Treasury guidance.
Activities & Publications
November 14, 2023
Cravath partner Andrew T. Davis participated in the 82nd Institute on Federal Taxation, which was hosted by the New York University School of Professional Studies from November 12‑17, 2023, in Berkeley, CA and hosted leading professionals to discuss the latest trends and developments in federal tax matters. Andrew spoke on a panel entitled “S Corporations - Not So Simple In Practice,” which examined the tax‑related challenges and opportunities encountered in M&A transactions involving S corporations.
Activities & Publications
July 05, 2023
On June 30, 2023, Cravath partner Andrew T. Davis was featured in Bloomberg Tax’s “Spotlight” series, which “highlights the careers and lives of tax professionals around the world.” In an accompanying Q&A, Andrew explained his focus on the tax aspects of M&A transactions, spoke to his educational background including how his research in Russian literature and applied mathematics informs his tax practice, and noted the impact of recent tax policy changes on corporate clients. Asked to contemplate the best tax or financial advice that anyone ever gave him, Andrew reflected on advice from his uncle: “My uncle, an oncologist, once described the three A’s of what it takes to be a successful young doctor: availability, affability, and ability, in that order. I think that advice equally applies to young tax practitioners—more than anything else, we should be a steady source of advice and support in working through complex, and sometimes anxiety-inducing, tax questions.”
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