International Tax

• Advised a major U.S. private equity fund in connection with its international investment advisory structure, permanent establishment issues, and transfer pricing issues.
• Advised on structuring and U.S. international tax issues in connection with a joint venture for the importation of Liquefied Natural Gas, perhaps one of the biggest transactions in the country/world in 2010.
• Advised a global food processing and commodities trading corporation on several joint ventures, including a multi-billion dollar pan-Asian commodity trading structure.
• Provided U.S. tax and corporate advice in connection with the restructuring of a U.S.-based publically-traded multinational company’s exchange and rentals business unit that involved five different European countries.
• Provided U.S. tax advice on a several billion dollar, public acquisition of a multinational group of companies, including issues arising under the Foreign Investment in Real Property TaxAct and the passive foreign investment company regime, as well as certain unique potential consequences of the inversion legislation.
• Advised a Fortune 25 public company with respect to structuring a cross-border oil and gas joint venture including addressing U.S. trade or business and effectively connected income issue, title passage, and transportation income issues.
• Advised a public manufacturing company in connection with a multinational acquisition, including performing international due diligence.
• Advised a major media firm in connection with an offshore acquisition, including analyzing the effects of Sections 367 and 1248 on the seller.

Treaties

• Provided advice and expert testimony in connection with the application of the U.S.-Australia Income Tax Treaty in connection with certain claims raised by the Australian Tax Authority in a bankruptcy case.
• Reorganized the U.S. holdings of the U.K. subsidiaries of a Japanese bank in response to changes in the U.S.-U.K. treaty, including consultation with the U.S. Competent Authority to obtain relief.
• Evaluated permanent establishment issues under the treaties with 13 different jurisdictions in connection with toll manufacturing operations for a major manufacturing firm.

Controversy

• Represented a Public Commodities Company, 2013 on a tax refund claim in connection with a hedging issue.
• Worked on behalf of a Public Company to receive two favorable private letter rulings from the IRS National Office for a regulated public utility, securing the company the benefit of a current deduction relating to renewable energy credits.
• Received a 100 percent concession by IRS Examination Division for a worthless stock deduction, securing the company a deduction in amount more than $50 million on behalf of a Public Company.
• Litigated with respect to whether severance payments due to involuntary workforce reductions qualify as wages for FICA purposes, similar to the Quality Store case, on behalf of a multinational and a leading global manufacturer.
• Representation of a foreign corporate taxpayer in connection with whether it was engaged in a U.S. trade or business through a permanent establishment in the United States.
• Representation of U.S. corporate taxpayers in connection with the taxation of the receipt of anti-dumping duties imposed on foreign corporations.
• Advice to corporate taxpayers in connection with proposed adjustments on lease-in lease-out transactions involving tax-indifferent parties.

Financial Transactions

• Created a U.S.-U.K. tax-efficient financing structure using notional contracts for an Australian banking concern.
• Advised a U.S. branch of a foreign bank in connection with subpart F and effectively connected income issues in connection with a financing arrangement.
• Advised a foreign securities trading firm in connection with effectively connected income issues and the characterization of total return swaps.
• Analyzed a Netherlands Antilles finance company in the context of a sophisticated global cash management structure for a Fortune 100 manufacturer.
• Advised a major investment banking firm and its clients in connection with the repatriation of earnings held overseas, including the effects of recently passed legislation.
• Provided advice with respect to the U.S. income and withholding tax aspects of collection and repatriation of over $1.5 billion in U.S. assets for a high profile foreign financial institution in liquidation.
• Evaluated and implemented a captive insurance company structure for a privately held manufacturing company.
• Provided advise in connection with subpart F issues in connection with a currency coordination center for a publicly traded U.S. company.

Structuring

• Restructured $100 million of debt on behalf of a Fortune 1000 client’s ownership business in Australia.
• Advised as lead U.S. federal tax advisor on transaction including foreign tax credit implications associated with restructuring of Canadian operations.
• Provided international tax structuring advice and analysis in connection with proposed exit of an Australian entity on behalf of a firm client.
• Advised a Fortune 100 company on the implementation of a global holding company structure in Europe, Asia, South America, and Central America.
• Advised a U.S. technology company on the efficient deployment of its intellectual property and manufacturing and service operations in connection with joint ventures in the Philippines.
• Advised a computer software development company with respect to structuring its international intellectual property holdings and international sales and services licensing operation in the United States, Canada, Mexico, Europe, Asia, and Africa.
• Provided significant U.S. tax savings for a public Canadian company by reorganizing its U.S. holdings, including obtaining a ruling from the Internal Revenue Service.
• Designed an efficient foreign tax credit structure for U.S. investors in hydroelectric power in Brazil, working closely with a local Brazilian firm in determining available local incentives.

Transfer Pricing

• Implemented a cost sharing arrangement and advised with respect to an offshore holding company with respect to intellectual property for a multi-national manufacturing company and separately for a multi-national hospitality company.
• Consulted and provided transfer pricing advice and drafted relevant agreements in connection with an entertainment firm’s services structure.
• Prepared master services agreements for a global logistics and transportation firm.
• Prepared master software license agreements for the charge-out of software fees for a major commodities firm.
• Advised on the transfer of intangible assets and implementation of a cost-sharing arrangement for a privately held U.S. entity developing state-of-the-art data storage products with key personnel in Russia.
• Consulted with accounting firms and provided advice in connection with transfer pricing studies prepared on behalf of a client in connection with novel transfer pricing issues raised by a transaction with no current market comparables.
• Provided ongoing transfer price advice for U.S. subsidiaries of a large Japanese manufacturer, including advice about purchases and sales, the use of intangible property and research and development.