Tax

Tax planning and structuring to achieve tax efficiency for in-bound investments, including acquisitions, dispositions and financing transactions; advising on compliance with relevant tax laws and regulations, including intercompany transfer pricing; responding to inquiries of tax authorities and resolving tax disputes.

Representative tax assignments (see also ‘Attorneys‘):

* We routinely represent Gulf investors (including foreign government agencies) in their participation in private equity funds and other collective investment vehicles, including the design and establishment of tax-efficient holding structures and the negotiation and inclusion of favorable tax provisions in the investment documentation.

* We have developed a specialization in these matters representing foreign sovereign agencies and instrumentalities (including sovereign wealth funds) in structuring their investments to leverage their sovereign status and achieve tax efficiencies wherever possible.

* We have advised foreign airlines and shipping companies regarding the U.S. tax rules applicable to transportation income.

* We have represented multiple foreign companies and their U.S. subsidiaries with respect to intercompany pricing cases undertaken by U.S. tax authorities.