Notable Representations

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OUTCOME:

- Represented foreign private equity fund in tax-efficient structuring and negotiation of terms of numerous real estate investments in Chicago, as well as their acquisition of companies in the health, ... entertainment, and various other industries in the U.S. - Represented Chinese company in the development of a geothermal power plant in California and advise on the US federal tax aspects of formation and operation, US-Chinese income tax treaty considerations, privacy considerations, and tax-efficient repatriation of the profits. - Represented US company developing $500,000,000+ credit facility in Mexico and advise on US tax-efficient structuring including Controlled Foreign Corporation (“CFC”) implications, subpart F income, planning for the Global Intangible Low-Taxed Income (“GILTI”), and tax implications of exiting the investment and repatriation planning. - Represented a US company’s acquisition of a Spanish company and advise on US tax aspects of the acquisition and coordinate with Spanish tax professionals regarding the Spanish implications of the acquisition and other Spanish tax issues. - Represented the private wealth department of a Japanese bank moving high net worth investment portfolios to the U.S. and advise on the U.S.taxation of nonresident aliens, tax planning opportunities, and withholding tax and compliance requirements.