International Tax Strategies
Our International Tax Strategies team utilizes our integrated worldwide network to combine domestic and cross-border tax advice. As clients implement their investment decisions our team delivers clear recommendations as to the most appropriate tax structure for the situation – delivering efficiency consistent with business reputation and international tax norms.
Our expertise includes:
- Advising on issues including international tax planning, transfer pricing, domestic and cross-border M&A and joint ventures, foreign tax credit pooling, global tax optimization, compliance and dispute resolution.
- Counseling on corporate and private equity transactions; debt and equity fund raising, refinancing and restructuring; real estate investment and development; as well as tax controversies and disputes.
- Utilizing our global platform to provide in-depth knowledge of national and international tax regimes and structures.
- Providing tax structuring advice to sovereign and other institutional investors in connection with cross-border investments (both direct and through managed funds) they make to provide capital for real estate, infrastructure, energy, private equity and other economic sectors.
Employee Benefits and Executive Compensation
Our Employee Benefits and Executive Compensation team is positioned to cover all aspects of a client’s needs in connection with executive compensation plans and arrangements. Our clients include many multinational publicly-held Fortune 500/ FTSE 100 companies.
We advise clients across a range of industries and, utilizing our global footprint, we design and implement executive compensation plans across multiple jurisdictions. We are particularly adept at assisting our clients with the public company implications of executive compensation and the increasingly complex governance issues that arise. The breadth of our international client base and experience allows us to handle any executive compensation matter.
Our lawyers provide practical problem solving, proactive planning and sophisticated analyses in addition to basic benefits work. Areas of our major capabilities include:
- Equity and other executive compensation plans.
- Deferred compensation and retirement plans.
- Executive contracts and compensation.
- Mergers and acquisitions.
- International employee compensation and benefits matters.
The Private Wealth team provides advice to a wide range of clients on transferring personal wealth and ownership of businesses from generation to generation, using structures and strategies that minimize income, gift, estate and generation-skipping transfer tax costs.
We also assist trustees, executors and beneficiaries in complying with tax-reporting requirements and in resolving matters that involve potential or actual litigation over trusts, estates or other family wealth holding structures.
Our clients include high-net-worth individuals and families, business owners, top executives of major corporations, regional and international banks and trust companies, and charitable organizations.
Our expertise includes:
- Implementing tax-effective wealth-transfer and asset-protection strategies.
- Succession planning for family-controlled businesses.
- Advising fiduciaries for trusts and estates.
- Preparing US estate tax returns, gift tax returns and generation-skipping transfer tax returns, and US fiduciary income tax returns, and defending tax audits.
- Tax domicile and residency matters and defending relevant tax audits and litigation.
- Trust administration matters and tax-law reporting requirements.
- Representing trustees, executors and beneficiaries in disputes and litigation.
- Advising on charitable giving strategies, and in establishing charitable trusts and nonprofit companies.
We have a long history advising governmental, nonprofit and for-profit borrowers, as well as underwriters and financial advisors, on the federal and state tax aspects tax-advantaged (tax-exempt and tax credit) financing of capital assets and working capital.
In addition to serving as bond counsel to issuers and issuing the favorable tax opinion upon issuance of the debt, our expertise includes:
- Structuring transactions to satisfy requirements for tax-exempt and tax credit debt.
- Advising commercial and investment banking institutions that purchase or underwrite the debt of borrowers and that provide credit enhancement and derivative products related to debt issuances.
- Representing issuers before the Internal Revenue Service in connection with private letter ruling requests with respect to prospective bond issues, audits of outstanding tax-advantaged bonds, and requests of “closing agreements” where the issuer has not satisfied all of the ongoing tax requirements after issuance of such bonds.
US Tax Policy
We have been consistently recognized as Washington DC’s top public policy and regulatory advocacy law firm. Our tax and public policy practitioners have worked for decades advocating before the Executive and Legislative branches of the US Government at all levels to assist individual companies, trade associations and industry groups achieve desired outcomes under the federal tax code. We have represented client interests in connection with virtually every major tax bill enacted since 1969. Our Tax Policy team includes many former government officials, both legislators and regulators, as well as industry leaders, and our bipartisan expertise means that we have unmatched experience navigating tax issues before the Administration and Congress.
The substantive areas covered by our client representations have been as varied as the tax code itself, including issues related to international tax, real estate, capital cost recovery, financial institutions and financial products, investment income and a broad range of investment vehicles, general business tax, employee benefits, and estate and gift tax. The depth of our technical tax expertise within our global tax practice, coupled with the firm’s political and policy capabilities, enables us to provide our clients with sophisticated strategic counsel on a wide range of tax planning matters.