International Tax

We provide clients with pragmatic solutions to complex international tax matters related to:

• Cross-border mergers and acquisitions
• Cross-border partnerships or joint ventures
• Group planning for multinational corporations
• Inbound and outbound investments to and from the United States 

We often encounter complex questions that require thoughtful analysis and judgment. Drawing on our tremendous experience and global presence, we help clients successfully navigate tax issues related to:

• Optimizing a global tax structure
• Addressing potential risks of challenges by tax authorities
• Transfer pricing matters
• Intercompany debt

• Adecco Group in its US$212 million acquisition of Drake Beam Morin, Inc., a leading career transition and talent development services provider, from Compass Partners International Limited
• AXA Private Equity and Permira, respective owners of the on-line travel agencies Go Voyages and eDreams, in the acquisition of the Opodo group, a UK headed group of online travel agencies 
• Broadcom Corporation in its US$83 million acquisition of Gigle Networks Inc., a company that develops system-on-a-chip (SoC) solutions for home networking over power lines
• Acquisition of Brookfield Renewable Fund, a Québec-based open-ended income trust, by Brookfield Asset Management Inc. valued at US$13 billion
• The Carlyle Group in its US$4.3 billion acquisition with Hellman & Friedman LLC of Pharmaceutical Product Development, Inc., a contract research organization providing drug discovery, development and life-cycle management services
• Citic Securities Company in its HK$14 billion initial public offering of approximately 1 billion H shares listed on HK Stock Exchange
• Digital Generation, Inc. (formerly DG FastChannel, Inc.) in its US$66 million acquisition of the outstanding limited liability company interests of EyeWonder, LLC, and chors Gmbh, two providers of interactive digital advertising products and services
• Sale by GE Capital of 49.77% of the equity of Banco Colpatria, a Columbian bank, to Mercantil Colpatria, with a transaction value of US$5.5 billion
• Global World-Check, a provider of critical risk intelligence services, in its acquisition by Thomson Reuters from Spectrum Equity Investors
• GTCR LLC in its US$275 million acquisition of Global Traffic Network, Inc., a provider of traffic and news information to radio and TV stations outside of the US
• Hapag-Lloyd AG in its US$703 million offering of €330 million 9.00% senior notes due 2015; and US$250 million 9.75% senior notes due 2017
• Imerys in Micral S.A’s $340 million acquisition of Luzenac Group's talc assets, a talc mining and processing company operating under Rio Tinto's Industrial Mineral segment
• Mattel, Inc., in its $680 million acquisition of HIT Entertainment Limited, a UK-based children's entertainment producer and rights-owner    
• Norsk Hydro ASA in its US$5.27 billion acquisition of Vale SA's aluminum business
• The Royal Bank of Scotland (RBS) as agent in connection with the restructuring of Synventive Molding Solution, a designer and manufacturer of hot runner systems in the molding industry
• SABMiller Plc on US and UK tax aspects in connection with its acquisition of Fosters Group Ltd., an Australian brewing and soft drink company. This deal is one of the largest announced M&A transactions worldwide in 2011 and one of the largest Australian-targeted M&A transactions on record.
• Salvatore Ferragamo in its €379 billion initial global offering of 38,275,000 ordinary shares listed on the Mercato Telematico Azionario        
• VAC Luxembourg S.a.r.l., a portfolio company of One Equity Partners LLC that produces magnetic materials and related products, in its US$1 billion sale to OM Group, Inc.
• The Yucaipa Companies, LLC, in its acquisition of Soho House Limited, the UK-based private members club for those in film, media and creative industries