International Tax

We regularly advise multinational clients in structuring acquisitions and foreign operations so as to lessen worldwide taxes and facilitate the tax-efficient repatriation and reinvestment of earnings. With our extensive cross-border transactional experience, our lawyers help clients develop cross-border sales and financing strategies that minimize Subpart F income and maximize foreign tax credit relief for non-U.S. activities, including hybrid debt/equity capital structures.

We regularly help clients form tax-efficient international holding companies with sales, service and distribution affiliates in multiple foreign countries, including offshore jurisdictions that offer tax-incentives and opportunities for implementing appropriate tax minimization strategies. In addition, we help clients structure cross-border mergers and acquisitions, including forming special acquisition companies and utilizing tax-advantaged strategies.

In support of our privately held business clients, we counsel companies wishing to develop or expand operations abroad. We provide advice on myriad business and legal issues related to foreign commerce, including tax incentives and trade grants. In addition, we assist clients in negotiating third-party manufacturing, distribution, and licensing agreements, and we help clients develop a tax-efficient strategy for integrating their expanding foreign operations with their existing domestic business enterprise.

In addition to advising U.S. clients on their foreign activities, we also represent foreign individuals and foreign corporations that are planning investments or business activities in the United States. In these cases, we help clients create business entities and structure transactions that comply with applicable federal and state requirements while minimizing the aggregate tax burden imposed under applicable statutes and tax treaties.