Print
Professionals
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z
Name
Advanced Search…
Government Experience…
Experience
Practices
Industries
Regions
A–Z
C&M International
Crowell Health Solutions
Locations
Brussels
Chicago
Denver
Doha
Indianapolis
London
Los Angeles
New York
Orange County
San Francisco
Shanghai
Washington, D.C.
C&M International
Singapore
Washington, D.C.
Insights
Events
Firm News
Client Alerts & Newsletters
Articles & Publications
Press Coverage
Speaking Engagements
Podcasts
Blogs & Microsites
About
Leadership
Mission
Collaboration
Innovation
Supplier Diversity
Recognition
Diversity, Equity and Inclusion
Pro Bono
Careers
Lawyers
Law Students
Professionals
Professionals
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z
Name
Location
All Locations
Brussels
Chicago
Denver
Doha
Indianapolis
London
Los Angeles
New York
Orange County
San Francisco
Shanghai
Singapore
Washington, D.C.
Washington, D.C.(CMI)
Practice
All Practices
Advertising and Media
Antitrust and Competition
Aviation
C&M International
Corporate and Transactional
Crowell Health Solutions
E-Discovery and Information Management
Environment and Natural Resources
Environmental, Social, and Governance
Financial Services
Government Affairs
Government Contracts
Health Care
Infrastructure
Insurance / Reinsurance
Intellectual Property
International Dispute Resolution
International Trade
Investigations
Labor and Employment
Litigation and Trial
Mass Tort, Product, and Consumer Litigation
National Security
Privacy and Cybersecurity
Recovery
State Attorneys General
Tax
White Collar and Regulatory Enforcement
Industry
All Industries
Aerospace and Defense
Aviation
Education
Energy
Financial Services
Food and Beverage
Health Care
Hospitality and Leisure
Life Sciences
Retail and Consumer Products
Technology
Transportation
Advanced Search…
Government Experience…
Experience
Practices
Industries
Regions
A–Z
C&M International
Crowell Health Solutions
Search By Name
Locations
Brussels
Chicago
Denver
Doha
Indianapolis
London
Los Angeles
New York
Orange County
San Francisco
Shanghai
Washington, D.C.
C&M International
Singapore
Washington, D.C.
Insights
Events
Firm News
Client Alerts & Newsletters
Articles & Publications
Press Coverage
Speaking Engagements
Podcasts
Blogs & Microsites
About
Leadership
Mission
Collaboration
Innovation
Supplier Diversity
Recognition
Diversity, Equity and Inclusion
Pro Bono
Careers
Lawyers
Law Students
Professionals
Tax
Professionals
Contacts
Representative Matters
News & Events
Related Practices
Transactional Tax
ERISA and Employee Benefits
International Tax
Partnership Tax
State and Local Tax
Tax Accounting
Tax Audits, Appeals & Litigation
Emerging Companies and Venture Capital
Environmental, Social, and Governance
Securities Fraud and Financial Investigations
Managing Tax Audits and Appeals
Practices
›
Tax
›
Transactional Tax
›
Representative Matters
Transactional Tax
Contacts
Charles C. Hwang
Partner
Washington, D.C.
+1.202.624.2626
chwang@crowell.com
Representative Matters
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.