International Taxation

Attorneys in Taft’s International Tax practice have extensive experience in helping clients plan for and manage the complexities of operating in international commerce. We have assisted clients with both inbound and outbound investment transactions, including multi-billion dollar taxable acquisitions of foreign targets by domestic corporations, acquisitions and dispositions of foreign targets by private equity firms, tax-deferred reorganizations involving foreign corporations with U.S. owners, and the start-up of U.S. operations by foreign companies. The scope of our services includes everything from the provision of formal tax opinions to the review of proposed transactions for purposes of identifying risks and opportunities.

In addition, our attorneys routinely assist clients with meeting the ever-changing technical reporting requirements associated with U.S. tax compliance. This work often includes assisting both domestic and foreign clients with identifying and completing annual filing obligations, obtaining documentation to take advantage of treaty-based tax savings, and assisting with withholding tax determinations with respect to cross-border payments.

Fundamental to our approach to advising clients on international tax issues is the core belief that tax advice must not be given in isolation from the greater transaction. Attorneys in Taft’s Tax practice work across our various practice groups and with our clients to foster an understanding of how the tax implications of a transaction integrate with the transaction as a whole. Accordingly, by viewing tax planning through the prism of the greater transaction, we are able to deliver to our clients a seamless business solution that brings to bear all of the capabilities of a full service law firm, including international tax experience.

Recent representative engagements include:

• Represented foreign publicly traded company with respect to its U.S. subsidiaries income tax audit and before the IRS Office of Appeals.
• Represented U.S.-based private equity firm with dividend recapitalization of foreign portfolio company.
• Assisted private company with IPO transaction on a foreign stock exchange.
• Represented publicly traded company before the IRS Office of Appeals, achieving favorable settlement.
• Assisted publicly traded company with restructuring of foreign operations and divestiture of non-key assets.
• Assisted publicly traded company with refinancing of public and private debt.
• Assisted FORTUNE 500 public company with multibillion dollar taxable acquisition of a foreign target.
• Prepared a pre-filing agreement request for submission to the Internal Revenue Service concerning matters related to foreign currency hedging and representation of the client during the pre-filing agreement process.
• Represented foreign commodities-trading concern in connection with the establishment of a U.S. trading desk.
• Represented U.S. manufacturing concern in the establishment of its first foreign operations in Canada.
• Assisted publicly traded company with foreign tax credit matters stemming from IRS audit.
• Represented U.S.-based private equity firm in connection with the acquisition of a foreign target.
• Representation of a public FORTUNE 500 company with respect to the disposition of assets located in multiple foreign jurisdictions.
• Represented private equity firm with the disposition of a foreign portfolio company.
• Representation of multiple individuals seeking to take advantage of the voluntary disclosure initiatives established by the IRS with respect to the reporting of foreign accounts.
• Representation of multiple clients with respect to the formation of a domestic international sales company (DISC) and the corresponding implementation of the intercompany arrangements associated with such operations.
• Representation of public FORTUNE 500 company concerning the repatriation of foreign earnings.
• Assisted public company with the implementation of a foreign currency hedging program.
• Assisted closely-held domestic corporation with the sale of its foreign subsidiaries and directly held foreign assets in taxable transaction.