We often render advice to foreign nationals, U.S. and foreign businesses about the ongoing personal and operational issues facing businesses and individuals with tax nexus, operations and/or assets in multiple jurisdictions. In today's increasingly global business and investment community, many businesses and investors must consider the tax business and regulatory framework of multiple states or countries. We guide clients through the competing considerations between different states or countries of legal residency, and the differing advantages of acquiring or establishing a business in one or more locales.
We counsel individuals and businesses from around the world on international tax matters and investment and disposition opportunities. Our goal in counseling our clients is worldwide tax minimization through lawfully available means. We may minimize worldwide tax liabilities of U.S. multinational and foreign clients through internal restructurings, imaginative hybrid entities, the acquisition or establishment of a business in foreign locales, and novel cross-border transactions.
Much of our practice involves U.S. tax issues, and we have provided advice on such domestic tax issues to Austrian, Belgian, Brazilian, Canadian, Chinese, English, German, Iraqi, Irish, Israeli, Japanese, French, Ghanian, Kenyan, Manx, Mexican, Russian, Singaporean, South African, Spanish, Swiss, and Thai investors and businesses. In many cases, not only U.S. tax issues and/or home country tax issues (or coordination with local tax counsel) are considered. Frequently, various U.S. state tax issues must be taken into account in an integrated fashion.
As Robert W. Wood is admitted to practice as a Solicitor in England and Wales, we have counseled clients on the U.K. tax aspects of domestic U.K. tax issues and transactions, and on a variety of cross-border transactions involving the U.K., various EU and other European countries, Australia, Canada, Japan, etc. He is also a member of the Canadian and Australian bars, and we have advised clients on the tax aspects of cross-border transactions in those countries, either on our own or working in tandem with local counsel where required.
Our expertise covers a wide array of cross-border and multinational transactions, including: international mergers and acquisitions, dispositions, joint-ventures, and restructurings to reduce multinational tax exposure. We have structured and negotiated a number of tax-sensitive cross-border merger and acquisition transactions and tax-free reorganizations. With our lawyers representing membership of the bars of California, New York, the District of Columbia, Ohio, Arizona, Montana, Washington, Texas, and Wyoming (as well as England, Wales, Canada and Australia), we are qualified to handle tax matters at the administrative level and in court in many states, and even foreign countries.
Representations have included the following:
References available on request.
Advised a number of U.S., South American, Indian, Canadian, Australian, British, South African, German and other investors on tax issues relating to their tax status, their tax domicile and/or physical residency.