-
Represented non-U.S. investor in connection with US tax issues arising from U.S. growth equity investment.
-
Represented foreign investment bank in connection with U.S. tax issues arising from multiple leveraged stock and asset acquisitions.
-
Represented non-U.S. investors in connection with equity and debt investment transaction structured to meet portfolio interest exemption and related rules.
-
Represented non-U.S. investors in connection with U.S. tax issues arising in connection with leveraged acquisition by joint venture of U.S. multifamily properties.
-
Represented non-U.S. investor with U.S. tax issues (including the portfolio interest exemption and related rules) arising from acquisition of U.S. warehouse properties.
-
Represented offshore investment bank in connection with tax issues arising from establishment of offshore private equity fund, including issues arising from tax exempt and pension plan investors.
-
Represented offshore investment bank in connection with U.S. tax issues arising from establishment of U.S. subsidiary and advising as to extent of U.S. operations to mitigate likelihood of effectively connected income.
-
Represented high net worth U.S. persons resident offshore with personal income tax issues.
-
Represented non-U.S. family office in connection with tax issues arising from U.S. private equity investment.
The firm has devoted special attention to minimizing the tax impact on its U.S. clients doing business abroad as well as foreign institutions transacting business in the U.S. Our lawyers have had considerable experience in international transactions involving U.S. real property that are subject to the Foreign Investment in Real Property Tax Act (FIRPTA) and are well versed in the portfolio interest exemption, the earnings stripping rules and the complex rules of attribution especially important in cross-border transactions.
Related Information
Representative Matters
