David R. Hardy - McDermott Will & Emery


David R. Hardy focuses his practice on corporate and international tax, particularly in the energy industry. He handles cross-border merger transactions, including public company stock acquisitions, joint ventures, project financings, cross-border security issuances, inbound and outbound securities, real estate and private equity partnerships.

David is a frequent speaker and author on various tax-related topics, and has been the principal author of several NYS Bar Tax Section reports. He has written on the base erosion and anti-abuse tax, the anti-double dip finance provisions, the anti-hybrid provisions of the US-Canada treaty, the non-recognition rules regarding the outbound transfers of intangible property, and the consistency principle in tax treaty interpretation.


  • Developed and implemented a multi-billion dollar tax advantaged intragroup restructuring for a major publicly traded North American company*
  • Structured a multi-billion dollar combination of two US groups of a public European company*
  • Advised on a $400 million intragroup debt relief transaction with beneficial SRLY consequences*
  • Structured a $7 billion cross-border acquisition of intangible and operating assets*

*Matter handled prior to joining McDermott


  • Who’s Who Legal, Corporate Tax – Advisory (International), 2020
  • Super Lawyers, Tax, 2020


  • International Tax Institute of New York, past president
  • New York State Bar Tax Section, Executive Committee, member
  • Tax Committee of the International Bar Association, past Chair
  • Tax Committee of the ABA Infrastructure Committee, past Chair


New York University Law School, LLM Taxation, 1979
Georgetown University Law School, JD, 1975
Reed College, BA, Phi Beta Kappa, 1971

New York
New Hampshire