International Tax

In addition to publicly traded and privately held companies, our tax practice represents a number of private equity firms of all sizes, including some of the largest private equity firms in the world. We work closely with fund formation and transactional attorneys to ensure that our clients’ funds and transactions are tax efficient for U.S. purposes. We advise our clients on acquisitions, dispositions, refinancings, portfolio company debt purchases and bolt-on acquisitions, and management company transactions.

Our tax team has significant experience advising international clients on the calculation of earnings and profits (E&P), dividend determinations and repatriation transactions. In recent years, we have performed more than 150 E&P studies for clients ranging from Fortune 100 companies to portfolio companies of private equity firms. In performing an E&P analysis, we provide a detailed review of the corporate events, tax returns, acquisitions and dispositions, financial statements, and other documents, and, from this information, we populate an E&P schedule on a year-by-year and an entity-by-entity basis. This E&P schedule can then be used to determine whether a particular transaction results in taxable income to the various parties to the transaction. This analysis can be critical to determining taxes that will be due for a particular distribution or repatriation transaction.