Often, tax considerations influence our clients' decision to invest in or acquire assets in another country, including the United States. Whether tax or non-tax considerations are the focal point of our clients' decision-making process, proper tax planning and counseling are typically critical to their long-term success.
Bilzin Sumberg’s tax lawyers work closely with entities and high-net worth individuals in creating the most tax-efficient structures for both outbound investments into non-U.S. countries and inbound investments into the United States. Our outbound planning involves the minimization of local country taxation, the deferral of income earned outside of the United States, foreign tax credit planning, and the efficient repatriation of profits to the United States. Our inbound structuring involves the reduction or elimination of U.S. income taxes on U.S.-source passive income (including gain from the sale of U.S. real estate) and on income connected with a U.S. trade or business, and minimizing the risk of a non-U.S. taxpayer from being engaged in a U.S. trade or business.
Seated in one of the most international cities in the world, we are uniquely positioned to report on new and existing tax legislation and treaties that can impact the viability of foreign investment. We launched Taxes Without Borders as a resource for international companies, individual investors and their advisors, providing insight into maintaining the most efficient tax structures for their business.
The blog's Editor, Tax Partner Jeffrey L. Rubinger, dedicates his practice to counseling domestic and international entities and individuals in advanced international taxation issues.
Internal restructuring of hedge fund
Represented a multi-billion dollar energy trading hedge fund in connection with an internal tax restructuring that would allow certain U.S. investors to obtain long-term capital gain on a portion of the fund’s earnings relating to energy futures contract.
Tax planning for energy trading hedge fund
Represented an energy trading hedge fund in connection with international tax planning relating to investment by its Cayman feeder fund in a publicly-traded REIT by way of a total return equity swap.
Licensing agreements in Latin America
Structured and negotiated license and royalty arrangements in Europe and Central and South America.
Counsel to Israeli tech fund expanding global operations to Latin America
Advising Israeli technology fund on its plans to introduce Israeli technology into the South American market. Israeli companies, whose innovative products include cyber attack prevention, quick-acting paving sealants and virtual health care, will license their technologies to the Fund, which will then offer those technologies to companies in South America.
Costa Rican land sale
Represented U.S. individuals in a Costa Rican land sale.
Tax structuring of Brazilian trademark licensing company
Represented a Brazilian trademark licensing company in its tax structuring.
Sales tax deferring case
Represented a nightclub in an alleged sales tax deferring case with the Florida Department of Revenue.
Mezzanine fund investment in private label business
Represented a mezzanine fund in its investment in a private label business.
Mezzanine fund investment in a nutraceutical business
Represented a mezzanine fund in its investment in a nutraceutical business.
Inbound investments from high net worth individuals
Advised numerous non-U.S. based clients, including individuals and businesses from Mexico, Brazil, El Salvador, Nicaragua, Venezuela, France, Great Britain and Germany, regarding business investments in the United States.