Cravath’s London Office Moves to 100 Cheapside
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 recognized by Lawdragon as among the “500 Leading Dealmakers in America,” “500 Leading Global Tax Lawyers” and “500 X – The Next Generation.” He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is Vice Chair of the Corporate Tax Committee of the Tax Section of the American Bar Association. He frequently speaks on important developments in tax law, including for organizations such as the ABA, D.C. Bar, Federal Bar Association, Practising Law Institute (PLI) and NYU’s Institute on Federal Taxation. In particular, he is a frequent commentator on topics in corporate taxation such as the corporate alternative minimum tax (“CAMT”), having participated in events including PLI’s “Basics of International Taxation,” where he spoke on a panel entitled “Compliance with Minimum Taxes.” Mr. Davis authored “Private Equity Funds,” a Bloomberg Tax Management Portfolio, which is a flagship treatise on private equity fund transactions. He has also served as Lecturer in Law at Stanford Law School, where he has taught corporate income taxation.
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 recognized by Lawdragon as among the “500 Leading Dealmakers in America,” “500 Leading Global Tax Lawyers” and “500 X – The Next Generation.” He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is Vice Chair of the Corporate Tax Committee of the Tax Section of the American Bar Association. He frequently speaks on important developments in tax law, including for organizations such as the ABA, D.C. Bar, Federal Bar Association, Practising Law Institute (PLI) and NYU’s Institute on Federal Taxation. In particular, he is a frequent commentator on topics in corporate taxation such as the corporate alternative minimum tax (“CAMT”), having participated in events including PLI’s “Basics of International Taxation,” where he spoke on a panel entitled “Compliance with Minimum Taxes.” Mr. Davis authored “Private Equity Funds,” a Bloomberg Tax Management Portfolio, which is a flagship treatise on private equity fund transactions. He has also served as Lecturer in Law at Stanford Law School, where he has taught corporate income taxation.
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
Stanford Law School
Law360
Lawdragon
The Legal 500 US
Deals & Cases
December 22, 2025
On December 21, 2025, Clearwater Analytics (“CWAN”) announced that it has entered into a definitive agreement to be acquired in a transaction valued at approximately $8.4 billion by a Permira and Warburg Pincus‑led Investor Group (the “Investor Group”), with participation from Temasek. The Investor Group has key support from Francisco Partners. The Special Committee of the CWAN Board of Directors unanimously recommended this transaction and the CWAN Board of Directors subsequently approved this transaction. Under the terms of the agreement, CWAN stockholders will receive $24.55 per share in cash upon completion of the proposed transaction. Cravath is representing the Special Committee of the CWAN Board of Directors in connection with the transaction.
Deals & Cases
December 16, 2025
Cravath represented Graham Holdings Company in connection with its $500 million 144A/Reg. S senior notes offering. Graham Holdings Company is a diversified holding company whose operations include educational services, television broadcasting, manufacturing, healthcare, automotive dealerships and other businesses. The transaction closed on November 24, 2025.
Deals & Cases
December 16, 2025
Cravath represented the initial purchasers in connection with the $1.5 billion high-yield senior notes offering of United Rentals (North America), Inc., a subsidiary of United Rentals, Inc., the largest equipment rental company in the world at the time of the offering. The transaction closed on December 1, 2025.
Deals & Cases
December 09, 2025
On December 8, 2025, Paramount, a Skydance Corporation (“Paramount”), announced it has commenced an all-cash tender offer to acquire all of the outstanding shares of Warner Bros. Discovery, Inc. (“WBD”) for $30.00 per share in cash, equating to an enterprise value of $108.4 billion. Paramount’s proposed transaction is for the entirety of WBD, including the Global Networks segment. Cravath is representing Paramount in connection with the transaction.
Deals & Cases
December 01, 2025
Cravath represented the underwriters in connection with the $500 million registered senior notes offering of Polaris Inc. Polaris Inc. designs, engineers, manufactures and markets powersport vehicles and also designs and manufactures or sources parts, garments and accessories. The transaction closed on November 13, 2025.
Activities
December 12, 2025
On December 11, 2025, Cravath partner Andrew T. Davis participated in “Tax Strategies for Corporate Acquisitions, Dispositions, Spin‑Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2025,” a program presented by the Practising Law Institute from December 10‑12 in Los Angeles. The program reviewed the tax issues presented by major corporate transactions, including single‑buyer acquisitions of a division or subsidiary, multi‑party joint ventures, cross‑border mergers and complex acquisitions of public companies with domestic and foreign operations. Andrew spoke on a panel entitled “Impact of the Corporate Alternative Minimum Tax (“CAMT”) on M&A Transactions,” which explored the CAMT rules and consequences for taxable and tax‑free acquisitions and dispositions, including spin‑offs, and reviewed the calculation of alternative minimum taxable income and other key issues addressed or unaddressed by IRS guidance.
Publications
October 28, 2025
On October 28, 2025, Cravath prepared a memo for its clients entitled “Back to the Future: IRS and Treasury Reinstate pre‑2024 Guidelines for Spin‑Off Private Letter Rulings.” The memo examines the Internal Revenue Service’s recently released Rev. Proc. 2025‑30, which provides updated guidelines for taxpayers requesting private letter rulings from the IRS for tax‑free spin‑off and split‑off transactions under Section 355. Rev. Proc. 2025‑30 supersedes Rev. Proc. 2024‑24 and withdraws Notice 2024‑38 (together the “2024 Guidance”).
Publications
September 29, 2025
On September 15, 2025, Bloomberg Tax published “Private Equity Funds,” a Tax Management Portfolio by Cravath partners Christopher K. Fargo, Arvind Ravichandran and Andrew T. Davis that addresses material tax issues faced by private equity funds. The flagship treatise provides in‑depth, clear and commercial guidance on a variety of topics, including fund formation, private equity M&A, structuring of special investments and addressing the needs of special cases of investors, such as tax‑exempts, sovereign wealth funds and foreign investors.
Activities
July 23, 2025
Cravath partner Andrew T. Davis participated in “Basics of International Taxation 2025,” a program presented by the Practising Law Institute from July 22‑23 in New York. Andrew spoke on a panel entitled “Compliance with Minimum Taxes,” which discussed compliance with the OECD Pillar 2 rules and U.S. corporate alternative minimum tax (CAMT), including their impact on M&A transactions.
Activities
June 05, 2025
On June 5, 2025, Cravath partner Andrew T. Davis participated in the 2025 Texas Federal Tax Institute, which was held from June 4‑6 in San Antonio, Texas. The event brought together leading corporate, partnership and real estate tax professionals from across the United States to discuss cutting‑edge issues facing tax practitioners. Andrew spoke on a panel entitled “Buying and Selling S Corps,” which reviewed the tax considerations involved in acquiring and selling S corporations for both buyers and sellers, including assuring a buyer step up, minimizing concerns over a busted S election and maximizing capital gain to the seller.
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 recognized by Lawdragon as among the “500 Leading Dealmakers in America,” “500 Leading Global Tax Lawyers” and “500 X – The Next Generation.” He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is Vice Chair of the Corporate Tax Committee of the Tax Section of the American Bar Association. He frequently speaks on important developments in tax law, including for organizations such as the ABA, D.C. Bar, Federal Bar Association, Practising Law Institute (PLI) and NYU’s Institute on Federal Taxation. In particular, he is a frequent commentator on topics in corporate taxation such as the corporate alternative minimum tax (“CAMT”), having participated in events including PLI’s “Basics of International Taxation,” where he spoke on a panel entitled “Compliance with Minimum Taxes.” Mr. Davis authored “Private Equity Funds,” a Bloomberg Tax Management Portfolio, which is a flagship treatise on private equity fund transactions. He has also served as Lecturer in Law at Stanford Law School, where he has taught corporate income taxation.
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 recognized by Lawdragon as among the “500 Leading Dealmakers in America,” “500 Leading Global Tax Lawyers” and “500 X – The Next Generation.” He has been recognized for his work in the tax arena by The Legal 500 US.
Mr. Davis is Vice Chair of the Corporate Tax Committee of the Tax Section of the American Bar Association. He frequently speaks on important developments in tax law, including for organizations such as the ABA, D.C. Bar, Federal Bar Association, Practising Law Institute (PLI) and NYU’s Institute on Federal Taxation. In particular, he is a frequent commentator on topics in corporate taxation such as the corporate alternative minimum tax (“CAMT”), having participated in events including PLI’s “Basics of International Taxation,” where he spoke on a panel entitled “Compliance with Minimum Taxes.” Mr. Davis authored “Private Equity Funds,” a Bloomberg Tax Management Portfolio, which is a flagship treatise on private equity fund transactions. He has also served as Lecturer in Law at Stanford Law School, where he has taught corporate income taxation.
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
Stanford Law School
Law360
Lawdragon
The Legal 500 US
Deals & Cases
December 22, 2025
On December 21, 2025, Clearwater Analytics (“CWAN”) announced that it has entered into a definitive agreement to be acquired in a transaction valued at approximately $8.4 billion by a Permira and Warburg Pincus‑led Investor Group (the “Investor Group”), with participation from Temasek. The Investor Group has key support from Francisco Partners. The Special Committee of the CWAN Board of Directors unanimously recommended this transaction and the CWAN Board of Directors subsequently approved this transaction. Under the terms of the agreement, CWAN stockholders will receive $24.55 per share in cash upon completion of the proposed transaction. Cravath is representing the Special Committee of the CWAN Board of Directors in connection with the transaction.
Deals & Cases
December 16, 2025
Cravath represented Graham Holdings Company in connection with its $500 million 144A/Reg. S senior notes offering. Graham Holdings Company is a diversified holding company whose operations include educational services, television broadcasting, manufacturing, healthcare, automotive dealerships and other businesses. The transaction closed on November 24, 2025.
Deals & Cases
December 16, 2025
Cravath represented the initial purchasers in connection with the $1.5 billion high-yield senior notes offering of United Rentals (North America), Inc., a subsidiary of United Rentals, Inc., the largest equipment rental company in the world at the time of the offering. The transaction closed on December 1, 2025.
Deals & Cases
December 09, 2025
On December 8, 2025, Paramount, a Skydance Corporation (“Paramount”), announced it has commenced an all-cash tender offer to acquire all of the outstanding shares of Warner Bros. Discovery, Inc. (“WBD”) for $30.00 per share in cash, equating to an enterprise value of $108.4 billion. Paramount’s proposed transaction is for the entirety of WBD, including the Global Networks segment. Cravath is representing Paramount in connection with the transaction.
Deals & Cases
December 01, 2025
Cravath represented the underwriters in connection with the $500 million registered senior notes offering of Polaris Inc. Polaris Inc. designs, engineers, manufactures and markets powersport vehicles and also designs and manufactures or sources parts, garments and accessories. The transaction closed on November 13, 2025.
Activities
December 12, 2025
On December 11, 2025, Cravath partner Andrew T. Davis participated in “Tax Strategies for Corporate Acquisitions, Dispositions, Spin‑Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2025,” a program presented by the Practising Law Institute from December 10‑12 in Los Angeles. The program reviewed the tax issues presented by major corporate transactions, including single‑buyer acquisitions of a division or subsidiary, multi‑party joint ventures, cross‑border mergers and complex acquisitions of public companies with domestic and foreign operations. Andrew spoke on a panel entitled “Impact of the Corporate Alternative Minimum Tax (“CAMT”) on M&A Transactions,” which explored the CAMT rules and consequences for taxable and tax‑free acquisitions and dispositions, including spin‑offs, and reviewed the calculation of alternative minimum taxable income and other key issues addressed or unaddressed by IRS guidance.
Publications
October 28, 2025
On October 28, 2025, Cravath prepared a memo for its clients entitled “Back to the Future: IRS and Treasury Reinstate pre‑2024 Guidelines for Spin‑Off Private Letter Rulings.” The memo examines the Internal Revenue Service’s recently released Rev. Proc. 2025‑30, which provides updated guidelines for taxpayers requesting private letter rulings from the IRS for tax‑free spin‑off and split‑off transactions under Section 355. Rev. Proc. 2025‑30 supersedes Rev. Proc. 2024‑24 and withdraws Notice 2024‑38 (together the “2024 Guidance”).
Publications
September 29, 2025
On September 15, 2025, Bloomberg Tax published “Private Equity Funds,” a Tax Management Portfolio by Cravath partners Christopher K. Fargo, Arvind Ravichandran and Andrew T. Davis that addresses material tax issues faced by private equity funds. The flagship treatise provides in‑depth, clear and commercial guidance on a variety of topics, including fund formation, private equity M&A, structuring of special investments and addressing the needs of special cases of investors, such as tax‑exempts, sovereign wealth funds and foreign investors.
Activities
July 23, 2025
Cravath partner Andrew T. Davis participated in “Basics of International Taxation 2025,” a program presented by the Practising Law Institute from July 22‑23 in New York. Andrew spoke on a panel entitled “Compliance with Minimum Taxes,” which discussed compliance with the OECD Pillar 2 rules and U.S. corporate alternative minimum tax (CAMT), including their impact on M&A transactions.
Activities
June 05, 2025
On June 5, 2025, Cravath partner Andrew T. Davis participated in the 2025 Texas Federal Tax Institute, which was held from June 4‑6 in San Antonio, Texas. The event brought together leading corporate, partnership and real estate tax professionals from across the United States to discuss cutting‑edge issues facing tax practitioners. Andrew spoke on a panel entitled “Buying and Selling S Corps,” which reviewed the tax considerations involved in acquiring and selling S corporations for both buyers and sellers, including assuring a buyer step up, minimizing concerns over a busted S election and maximizing capital gain to the seller.
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