Tax

Representative Engagements

• Advised a publicly-traded software and information management company in its acquisition of a publicly-traded, multinational company.
• Advised a foreign investment fund regarding its investment in a U.S. private equity fund, including application of limitation of benefits article of tax treaty and U.S. income tax and Foreign Investment in Real Property Tax Act (FIRPTA) consequences.
• Counseled an international airline regarding federal and state income and state sales tax consequences of sale-leaseback of aircraft, including the impact of tax treaties.
• Completed a Tax-free "B reorganization" acquisition of a foreign IT security company.
• Counseled a broker-dealer on the restructuring of an unconsolidated subsidiary to make use of its net operating loss.
• Advised a foreign investment fund regarding its investment in a U.S. private equity fund and management company, including structuring carried interest provisions.
• Advised a leading high tech equipment manufacturer concerning the income and sales tax implications of a series of complex domestic and international restructuring transactions.