Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 1612 REGULATORY ADVOCACY We routinely submit private letter ruling requests to the IRS and provide comments to the Treasury on proposed tax regulations. Baker Botts tax lawyers know the ruling and commenting processes, and we have utilized that experience and knowledge and received favorable outcomes for our clients on a prompt basis. We have assisted clients on numerous occasions in preparing comments on proposed Treasury regulations on a myriad of topics and will submit comments on behalf of a single client, a group of clients, or a trade group, depending on the circumstances. Our team strategizes an approach for the case at hand. EMPLOYEE BENEFITS AND EXECUTIVE COMPENSATION We have a substantial practice in Employee Benefits and Executive Compensation, assisting clients with all aspects of compensation and benefit plans and programs under the Internal Revenue Code and ERISA, and with the myriad legal issues that impact employee benefits under federal labor and securities laws and state laws. intangible drilling cost rules and transactions involving tax partnerships to conceptual issues such as the pool-of-capital doctrine or the essence of the economic interest. PRIVATE EQUITY FINANCING AND FUNDS Baker Botts tax lawyers are experienced with the tax issues incident to the formation and operation of private equity funds. We suggest structures for investment in such funds, and we advise on issues related to recapitalizations and buy-outs of interests in such funds. Our lawyers develop structures that minimize unrelated business income tax (UBIT) issues related to tax-exempt investors, and we have particular experience with tax issues affecting real estate investment trusts (REITs). We advise clients on issues from both a domestic and an international tax perspective and have served as tax counsel to several funds created in Europe and Russia.