International Tax

As business becomes increasingly international at all levels, from the multinational 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 the experience to handle this complex interplay, while providing effective and useful advice and developing practical strategies.

Sullivan & Worcester has one of the largest international tax practices in the Northeast. The legal practice of many of our 30 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
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 holding company regimes in various foreign countries
reducing worldwide effective foreign tax rates
developing capital structures and repatriation strategies
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

Practice Profile (PDF)

Representative Client Work

Advised the U.S. shareholders of a large foreign investment management firm on how best to preserve tax deferral of non-U.S. income
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
Implemented a foreign reorganization involving 20 countries for a major publicly traded manufacturer
Assisted one of the world’s largest mobile telephone operators and several other telecommunications providers with various tax issues related to expansion into the United States and foreign markets
Provided international tax and structuring advice to one of the world’s largest asset management firms in connection with its $27 billion bid for a global media and entertainment company
Advised a large publicly traded chemical company in its $100 million acquisition of a Japanese company and through the creation of hybrid entities and use of internal leverage achieved significant annual foreign tax savings