In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.

SpaceX's xAI Acquisition

Musk announced Feb. 2 that SpaceX has acquired his artificial intelligence company xAI in a bid to launch space-based data centers, amid reported plans for an initial public offering that would value the aerospace company at more than $1 trillion.

A Gibson Dunn & Crutcher LLP team steering SpaceX includes partners Eric Sloan and Michael Cannon and associates Doug Bresnick and Austin Morris, who advised on tax aspects.

A Sullivan & Cromwell LLP team guiding xAI included partner Isaac Wheeler and associates Gregg Rader and Jackson Mariotti advising on tax matters.

In a Feb. 2 statement posted by SpaceX, Musk called the merger "the most ambitious, vertically integrated innovation engine on (and off) earth, with AI, rockets, space-based internet, direct-to-mobile device communications and the world's foremost real-time information and free speech platform."

The announcement came days after it was reported that SpaceX was considering a June initial public offering that would value the company at more than $1 trillion.

Devon-Coterra $58B Deal

Devon Energy and Coterra Energy said Feb. 2 they have agreed to merge in an all-stock transaction that implies a combined enterprise value of approximately $58 billion.

A Gibson Dunn team representing Coterra includes senior counsel Gregory Nelson and associate Nathan Sauers advising on tax aspects.

When the deal is completed, Devon shareholders will own approximately 54% of the combined company, while Coterra shareholders will own approximately 46% on a fully diluted basis, according to a Feb. 2 joint statement.

The transaction, which was unanimously approved by the companies' boards of directors, is expected to close in the second quarter of 2026, subject to regulatory approvals and certain conditions, the companies said.

Santander's $12B Webster Buy

Banco Santander SA and Webster Financial Corp. said Tuesday they've reached an agreement for Santander to acquire Webster as part of a cash-and-stock transaction valued at more than $12 billion.

A Wachtell Lipton Rosen & Katz team advising Webster includes tax partner Joshua Holmes.

In a statement Tuesday, Webster — the holding company for Webster Bank NA — said the transaction has an aggregate value of approximately $12.3 billion, based on Santander's closing stock price Feb. 2.

The transaction is expected to close in the second half of the year, subject to certain conditions, including regulatory and shareholder approvals, the companies said.