Experience

• International and Domestic Planning

  • Represented and represents numerous private and publicly traded life sciences industry company clients in planning, implementing and maintaining their international IP exploitation structures and business models for their worldwide operations.
  • Regularly serves in the role as outside “tax director” for early-stage and emerging market companies.
  • Annually provides transfer pricing advisory and documentation services to clients of all sizes, with a focus on practical compliance services for pre-profit global companies.
  • Engaged by multiple investment fund, private equity fund and venture capital fund clients for formations and post-formation transactional representations.
  • Participated as co-counsel on multiple buy-side, sell-side and equity/debt financings related to fund portfolio companies and early stage investment rounds.
  • Represented numerous privately held and publicly traded companies in multi-jurisdictional advisory matters, including restructuring of worldwide business operations in order to achieve global tax efficiencies in foreign jurisdictions while addressing US foreign tax provisions (Subpart F planning). Structured and advised on international business operation structures in order to achieve same.
  • Represented numerous companies in foreign tax credit planning to efficiently utilize foreign taxes paid in the context of foreign E&P deficits.
  • Represented private and publicly traded companies in multi-jurisdictional restructurings of their worldwide business operations in order to achieve foreign tax incentives, maximize transfer pricing efficiencies, and address foreign royalty withholding tax issues.
  • Represented international entertainment company and engaged in domestic, international, and foreign pre-merger tax and corporate planning in the context of required business separations and pre-merger organizational structuring in more than 50 jurisdictions.
  • Represented numerous publicly traded companies on multi-jurisdictional basis and performed post-acquisition tax planning for worldwide integration of target entity operations into acquiring company’s worldwide operations. Oversaw and coordinated corporate implementation of these multi-jurisdictional tax structures.
  • Represented numerous privately-held and publicly-traded corporations in transfer pricing planning and documentation studies, as well as representing numerous multi-nationals in day-to-day advisory capacity with respect to tax issues arising in their international and domestic operations.