Our international practice includes tax planning for businesses operating in multinational jurisdictions. We have extensive experience in international tax planning and structuring related to the acquisition of ongoing businesses, the formation of new business operations and joint ventures and project financings, and have recently been involved in transactions related to investments in Central and South America, Canada, Mexico, Africa, Europe and Kazakhstan.
International business combinations frequently involve exchange of stock registered in another country; we set up the deal structures that make such exchanges possible and advise shareholders on the tax treatment of the stock they receive. In non-stock combinations, such as establishing joint ventures with foreign partners, we ensure that the deal is structured to minimize the tax consequences. Where these combinations involve loans and letters of credit, we handle the tax issues that the borrower faces in its cross-border payments.
A critical aspect of international tax counsel is the tax treatment of royalties, dividends and interest generated by the operations, and we have working knowledge of the international treaty provisions that restrict many of the options ordinarily available to strictly domestic operations. Where such restrictions affect repatriation of assets, we recommend effective alternatives to minimize the tax burden involved. Our lawyers use sophisticated knowledge of foreign tax laws to recommend the optimum strategies involving corporate structure and operation and their effect on taxation.