Chinese Holding and Trading Structure
Advised Fortune 500 client in the restructuring of its Chinese operations, so as to integrate the resulting subgroup into an existing Luxembourg holding structure, have a joint Swiss-offshore financing vehicle facilitating the flow of funds between the new Chinese and Luxembourg subgroups and improve the tax efficiency of the group's USD 100 Mio International sourcing activities.
Dutch Tax-Deductibility - Restructuring
Advised US multinational regarding the tax issues faced by its existing Dutch structure and the changes required to obtain the deductibility from the group's Dutch operating income of previously non-deductible interest.
Lead counsel in an Austrian-Luxembourg reorganization resulting in substantial tax benefits for the US multinational group.
The firm coordinated all aspects of the transaction, including tax and corporate law issues involving 10 jurisdictions, the assessment of legal requirements and submission of all related filings in multiple countries.
Homeland Investment Act
Implemented structure to manage the income generated by a US-held Central American manufacturing enterprise and allow its redeployment outside the US or its distribution to the US shareholder at preferential tax rates.
US-Luxembourg Debt Capitalization
Coordinated the capitalization of multi-jurisdiction debt held by a privately owned U.S. multinational parent and a Belgian subsidiary into a Luxembourg-Swiss financing vehicle.
The firm supervised all aspects of the transaction, including the drafting of all corporate documentation, and advised regarding the various tax issues involved.