International Tax

As business becomes increasingly global, from the multinational enterprise to the sole proprietor, it is more likely than ever that your business will need to plan its tax strategy on an international basis. Due to the complex interplay between and among U.S. tax rules, non-U.S. tax rules and double-taxation treaties, properly integrated and cohesive tax planning is essential when business spans international borders. Sullivan & Worcester’s international tax attorneys have significant experience in handling this complex interplay and developing practical strategies for businesses engaging in cross-border transactions.

Sullivan & Worcester has one of the largest international tax practices in the Northeast. The legal practice of many of our 35 tax lawyers includes a significant international tax planning component, and four of our lawyers focus primarily in international taxation.

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

• Structuring tax-efficient international mergers, acquisitions, dispositions and reorganizations
• Designing cross-border financing strategies, capital structures, repatriation strategies and planning for foreign tax credit utilization
• Migrating intellectual property to tax-favored jurisdictions
• Maximizing opportunities for deferral of U.S. tax on foreign earnings using favorable non-U.S. holding company regimes
• Reducing worldwide effective foreign tax rates
• Documenting and defending intercompany transfer-pricing matters
• Assisting with cross-border real estate investments
• Advising sovereign wealth funds, foreign governmental pension plans and other foreign governments as to their U.S. investments, including real estate investments

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
• Advised U.S. and non-U.S. clients on structuring cross-border real estate investments ranging from $10 million to $600 million
• 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, 2020 Olympics in Tokyo and the 2024 Olympic bid by Los Angeles
• 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
• Converted 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. Frequently, we obtain 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; 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 generally 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 almost 30 years related to various U.S. tax issues of their foreign investments
• Restructured the Danish group of a $365 million publicly traded multinational leader in medical ultrasound development through the use of hybrid instruments and the establishment of a foreign holding company