Cross-Border Transactions
We advise U.S. and foreign clients on cross-border mergers and acquisitions, and their related tax and finance considerations. International business combinations frequently involve exchange of stock registered in another country; we set up the deal structures that make such exchanges possible and advise shareholders on the tax treatment of the stock they receive.
In non-stock combinations, such as establishing joint ventures with foreign partners, we ensure that the deal is structured to minimize the tax consequences, and make certain that the intellectual property and investment rights of our clients are protected. Where these combinations involve loans and letters of credit, we handle the tax issues that the borrower faces in its cross-border payments.