Chinese Holding and Trading
Structure
Advised Fortune 500 client in the restructuring of its
Chinese operations, so as to integrate the resulting subgroup into an existing
Luxembourg holding structure, have a joint Swiss-offshore financing vehicle
facilitating the flow of funds between the new Chinese and Luxembourg subgroups
and improve the tax efficiency of the group's USD 100 Mio
International sourcing activities.
Dutch Tax-Deductibility -
Restructuring
Advised US multinational regarding the tax issues
faced by its existing Dutch structure and the changes required to obtain the
deductibility from the group's Dutch operating income of previously
non-deductible interest.
Austrian Reorganization
Lead counsel in an
Austrian-Luxembourg reorganization resulting in substantial tax benefits for the
US multinational group.
The firm
coordinated all aspects of the transaction, including tax and corporate law
issues involving 10 jurisdictions, the assessment of legal requirements and
submission of all related filings in multiple countries.
Homeland Investment Act
Implemented structure
to manage the income generated by a US-held Central American manufacturing
enterprise and allow its redeployment outside the US or its distribution to the
US shareholder at preferential tax rates.
US-Luxembourg Debt
Capitalization
Coordinated the capitalization of
multi-jurisdiction debt held by a privately owned U.S. multinational parent and
a Belgian subsidiary into a Luxembourg-Swiss financing vehicle.
The firm
supervised all aspects of the transaction, including the drafting of all
corporate documentation, and advised regarding the various tax issues involved.