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Our tax lawyers excel at providing practical advice on complex international transactions and structures. We regularly advise on international tax matters of all types, including:

  • Group planning for multinationals
 
  • Cross-border acquisitions, reorganizations and joint ventures
 
  • Post-acquisition integration planning
 
  • Inbound and outbound investments
 
  • International capital market transactions
 
  • Derivatives and financial products
 
  • Expatriation transactions
 
  • Cross-border investment management structures
 
  • International tax controversies 

Our lawyers are widely recognized for their skills, innovative planning and understanding of business needs and objectives. Representative matters include ongoing advice to Fortune 500 companies on their international structures; advice to a Fortune 500 bank on Chinese treaty issues; the representation of a large Swiss multinational in the acquisition of a Silicon Valley-based company; the negotiation of APAs; applications for discretionary treaty relief; the representation of a Brazilian company in the creation of a multi-billion dollar joint venture with a European company; a victory at the Federal Circuit on a U.S.-U.K. treaty issue; advice to public and private companies in a variety of industries regarding the development, ownership and transfer of intellectual property; the evaluation of permanent establishment exposures; the representation of a Fortune 500 company in Tax Court litigation relating to its international capital structure; and advice to various companies on transfer pricing issues.