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The increasing global footprint of today’s public and private enterprises and individuals, in an era of unprecedented tax changes driven by digital innovation and governmental skepticism of traditional tax planning strategies, demands an agile and multifaceted international tax expertise.

Sullivan’s international tax attorneys have deep experience in managing the complex interplay between and among U.S. tax rules, non-U.S. tax rules and double-taxation treaties, and in developing practical tax-risk mitigation strategies for businesses engaging in cross-border transactions and operations.

Sullivan has one of the largest international tax practices in the Northeast. From our own specialists to leveraging our closely monitored global network of foreign tax firms and advisors, we are well-positioned to assist clients with their worldwide tax needs. We have the experience and expertise to act as a single point of contact for in-house tax departments and coordinate tax advice from multiple jurisdictions, all to ensure that inconsistencies between jurisdictions are resolved early and that important issues are not neglected.

Our annual Worldwide Tax Update and client alerts keep our clients up to date on important international tax developments. Our lawyers are frequent speakers at industry events and have been recognized in Chambers, Best Lawyers in America®, The Legal 500 U.S. and other guides to top-ranking law firms and tax practitioners.

Our tax specialists have extensive experience in strategic tax planning and implementation for a wide range of international business activities and taxes, including:

  • Cross-border M&A transactions, financings, licensing arrangements, and joint ventures
  • Tax-efficient structuring and restructuring of multinational businesses, including to address BEPS and MLI initiatives
  • Worldwide effective tax rate minimization, tax attribute utilization planning, tax-efficient intellectual property and value chain management
  • Cross-border REIT matters and other types of real estate funds/investments
  • Advising sovereign wealth funds, foreign governmental pension plans and other foreign governments as to their U.S. investments, including real estate investments
  • Structuring for private equity and other alternative investment funds
  • Planning for fintech and crypto businesses and investments
  • Multijurisdictional lending and distressed debt transactions
  • International trust and estate counseling for high-net-worth families, corporate executives and investment managers, including pre-U.S. residency tax planning and succession and exit planning for owners of privately held businesses
  • Global compensation and mobile workforce planning
  • Tax reporting and compliance, including assistance with FATCA, FBAR, ASC 740 documentation, DAC 6, E.U. Mandatory Disclosure Regime, country-by-country and other tax reporting requirements
  • Global tax controversy, litigation, voluntary disclosures related to offshore activities, and private letter rulings

Representative Client Work

  • Led a worldwide team of attorneys and other advisors to restructure foreign operations in 20 countries for a $2 billion public manufacturing company
  • Represented multiple credit fund managers in developing and documenting an approach to managing their effectively connected income exposure; structured multiple credit, distressed debt and infrastructure credit funds to mitigate U.S. net income taxation for multiple classes of investors
  • Advised on set up of investment management companies for private equity, venture capital, and hedge fund managers, including providing advice on structuring seed investments, incentive fee arrangements, carried interest, and related estate tax planning matters
  • Counseled U.S. and non-U.S. clients on structuring cross-border real estate investments ranging from $10 million to $10 billion
  • Advised numerous biotech and technology companies on cross-border withholding taxes, anti-deferral/controlled foreign corporation rules, cost sharing agreements, and transfer pricing issues in connection with their worldwide operations
  • Represented Irish sponsors in the structuring and formation of private, externally advised, blind pool U.S. REITs to raise capital in Ireland and invest in U.S. commercial real estate
  • Provided international tax and legal advice related to the running of the inaugural European Games held in June 2015 in Baku, the 2016 Olympics in Rio de Janeiro, the 2020 Olympics in Tokyo and the 2024 Olympic bid by Los Angeles
  • Converted several public C corporations to REITs, including thorough reviews of the company’s worldwide operations and assets and various structuring strategies as well as tax and securities advice related to the possible implementation of these strategies, in particular obtaining private letter rulings from the Internal Revenue Service in connection with the proposed REIT conversion
  • Advised a U.S.-based public multinational designer, producer, and marketer of a wide range of mechanical power transmission products in the transfer of its U.K. group to a Netherlands holding company, and later advised the same company in its $80 million acquisition of a Danish group, including the design of the financing strategy
  • Designed a tax-favored international financing strategy involving hybrid debt and then advised on the cross-border tax planning for a public Finnish company in the minerals and metal processing business on its stock acquisition of a U.S. company
  • Represented a $400 million publicly traded multinational company that designs, manufactures, and distributes valves and related products in the restructuring of its energy products segment through the formation of a Luxembourg holding company and a series of internally leveraged transactions using hybrid instruments
  • Represented a large group of private investors in obtaining private letter rulings going back decades and related to various U.S. tax issues of their foreign investments
  • Performed a global tax risk study for a large private equity group with the focus on workforce related issues, changes in tax nexus rules in multiple jurisdictions, developments related to challenges of hybrid debt/equity structures, and holding companies located in low-taxed jurisdictions
  • U.S. tax counsel to the first pure-play U.S. office REIT to be listed in Asia for its Singapore IPO, initial and subsequent investments, and ongoing U.S. tax compliance matters, including critical global restructuring in response to the shifting U.S. tax landscape
  • Assisted numerous startups and established players in the FinTech sector to provide cross-border tax advice on the implementation of blockchain
Viewpoints
All Viewpoints
International M&A and Joint Ventures: Key U.S. Taxation Issues
Douglas Stransky, leader of the firm’s Tax practice group, authored “International M&A and Joint Ventures: Key U.S. Taxation Issues” published by LexisNexis in June 2026. The practice-oriented treatise focuses on the U.S. tax implications of cross-border mergers, acquisitions and joint ventures and incorporates recent legislative changes and international tax developments. It includes practice aids and aims to provide professionals strategies in navigating the complexities of cross-border transactions in an evolving tax landscape. LexisNexis® Legal & Professional is a leading global provider of AI-powered analytics and decision tools.
Why the First U.S. Pope Should Expatriate Immediately
Lewis Greenwald and Eric Rietveld co-authored the article "Why the First U.S. Pope Should Expatriate Immediately" published by Tax Notes [sub. req'd] on May 19, 2025.  The article outlines several reasons why it may be in the best interest for newly elected Pope Leo XIV -- Robert Prevost, a U.S. citizen -- to immediately give up his U.S. citizenship in order to avoid U.S. federal income and gift and estate tax liability. Despite being the Bishop of Rome, as a U.S. citizen Pope Leo XIV is still subject to U.S. Internal Revenue Code which will impact his U.S. taxable income and could subject the Vatican's bank accounts to annual foreign bank account report filings. By expatriating from the United States, Pope Leo XIV could avoid these taxation issues.         
Douglas Stransky Publishes Treatise on Cross-Border Mergers, Acquisitions & Joint Ventures
Boston, MA – Sullivan & Worcester announces today that LexisNexis has published a treatise authored by Douglas S. Stransky, partner and leader of Sullivan’s Tax Practice Group. International M&A and Joint Ventures: Key U.S. Taxation Issues, is a comprehensive, practice-oriented treatise that examines the U.S. tax implications of cross-border mergers, acquisitions, and joint ventures. Written for practitioners, the treatise balances technical rigor with practical insight and provides guidance on complex tax considerations that arise in international transactions. Available in hard copy and e-book format, the work incorporates recent legislative changes and international tax developments, offering timely analysis for professionals operating in today’s rapidly evolving global tax environment. The only comprehensive, single-author treatise integrating cross-border M&A structuring, joint ventures, international tax regimes, transfer pricing, SALT, and compliance into one resource, eliminating the need to consult and synthesize multiple publications. “Cross-border transactions present increasingly complex tax issues that require both technical expertise and practical judgment,” Stransky said. “My goal is to provide a resource that not only explains the law, but helps practitioners apply it effectively in real-world situations.” Complete with practical tools and practice aids, the treatise equips tax advisors, attorneys, accountants, and corporate professionals with strategies to navigate the challenges of cross-border transactions and make informed decisions throughout the transaction lifecycle. More information is available at LexisNexis. About Sullivan Sullivan & Worcester (Sullivan) is a premier, AmLaw 200 international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

International Tax

Sullivan Shares Cross-Border Deal of the Year Award With Two Clients at M&A Advisor Awards

In November 2021, Sullivan together with its clients Merger & Acquisition Services, Inc., and International Transportation Marine Office, LLC (ITMA) received the Cross-Border Deal of the Year ($50 to $100 million) Award, at the 20th Annual M&A Advisor Awards in New York City. The award was given for the sale of ITMA to MS Amlin Underwriting Limited, a UK company. Don Kaitz retained his role as chairman of Arizona-headquartered ITMA, and the business continued to be led by Eric Kaitz, Chief Executive Officer. Earlier in 2021, Douglas Stransky and Michael Student, along with Merger & Acquisition Services Inc., advised ITMA and the Kaitzes.

Partner and head of Sullivan's International Tax Group, Douglas Stransky, commented, "We are thrilled to receive this honor and be together in-person with our clients and friends, Merger & Acquisition Services, Inc. and Don and Eric Kaitz, and proud to have collaborated with them on this sale."

Douglas S. Stransky and Michael J. Student

International Tax

International Tax

International Tax