Sullivan
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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
Untaxed at Marriage, Taxed at Divorce: Who Pays When a Cross-Border Joint Venture Ends
Douglas S. Stransky, partner and leader of the Tax Practice Group, has published the second post in his series for the LexisNexis blog, examining the U.S. tax consequences that surface when a cross-border joint venture ends. Using a hypothetical 50/50 venture between a U.S. manufacturer and a German strategic investing through a U.S. corporate blocker, the post explains how the Section 704(c) method choice buried in boilerplate moves real money between the partners, how the seven-year mixing bowl rules can turn an amicable separation into a taxable event and why the blocker structure that solved a classification problem at formation adds a level of tax at the exit. The lesson running through the piece is that these outcomes are set in the formation documents, years before anyone asks the question. The post draws on themes from his LexisNexis treatise, International M&A and Joint Ventures: Key U.S. Taxation Issues, which devotes a full chapter to the U.S. tax considerations of joint ventures alongside case studies and sample transaction provisions. Read the full post »
The Org Chart Was Wrong: Entity Classification, Tax Due Diligence and Who Pays When an International Deal Springs a Leak
Douglas S. Stransky, partner and leader of the Tax Practice Group, has published a new post on the LexisNexis blog examining a recurring problem in cross-border acquisitions: entity classification errors discovered in tax due diligence. Using a hypothetical fact pattern in which a target’s foreign subsidiary never filed its check-the-box election, the post explains why classification mistakes persist, how a missing Form 5471 can leave the assessment statute open indefinitely under Internal Revenue Code Section 6501(c)(8), and how deal parties allocate an exposure no one can quantify. Doug compares the four principal risk allocation tools, purchase price reductions, special tax indemnities, escrows, and tax insurance, and discusses how the choice among them plays out in practice. The post draws on themes from his LexisNexis treatise, International M&A and Joint Ventures: Key U.S. Taxation Issues, which pairs technical analysis with case studies, a cross-border tax due diligence checklist, sample acquisition agreement provisions, and guidance on tax insurance. Read the full post »
Sullivan & Worcester Shortlisted for International Tax Review Awards
Boston, MA – Sullivan & Worcester has been shortlisted for the International Tax Review (ITR) Americas Tax Awards 2026 for Massachusetts Tax Firm of the Year. Nominees will be recognized and winners will be announced at the ITR Americas Tax Awards gala on October 29, 2026, in New York. The annual ITR Americas Tax Awards celebrate the most accomplished and distinguished tax and transfer pricing teams across 35 jurisdictions worldwide. In addition to recognizing excellence in tax litigation and advisory work, the program honors firms that are leading the way in tax technology innovation, in regulatory and compliance practices and in fostering diversity, equity and inclusion within the profession. “We are honored to be recognized among the leading tax practices in Massachusetts,” said Douglas Stransky, leader of Sullivan’s Tax practice group. “This nomination reflects our team’s commitment to delivering practical, sophisticated and client-focused solutions to complex tax challenges.” Sullivan’s Tax practice provides sophisticated counsel and legal advice to companies on a wide range of state, federal and international tax issues. The firm’s team provides creative solutions for the entire spectrum of tax-related legal issues, including tax planning for corporate reorganizations, representing clients in high-stakes tax disputes and advising companies on matters before the Internal Revenue Service and state tax authorities. For more information about awards and finalists, visit International Tax Review. 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.
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.

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