International Tax

As business becomes increasingly global, from the multinational enterprise to the sole proprietor, it is more likely than ever that clients will need to plan their tax strategy on an international basis. Due to the complex interplay between and among U.S. tax rules, non-U.S. tax rules and double-taxation treaties, properly integrated and cohesive tax planning is essential when business spans international borders.

With one of the largest international tax practices in the U.S., ZAG-S&W’s lawyers have significant experience in handling this complex interplay and developing practical strategies for businesses engaging in cross-border transactions. Many of our tax lawyers focus on international tax planning, regularly advising on structuring tax-efficient international mergers, acquisitions, dispositions and reorganizations. A comprehensive array of services also includes migrating intellectual property to tax-favored jurisdictions, maximizing opportunities for deferral of U.S. tax on foreign earnings, assisting with cross-border real estate investments ranging from $10 million to $600 million, and much more.

Challenging highlights have included: leading a global team of lawyers and advisers to a $2 billion public manufacturing company in the restructuring of foreign operations in 20 countries; advising on the complex restructurings of U.S.-based and foreign multinationals; representing sovereign wealth funds, foreign governmental pension plans and other foreign governments as to their U.S. investments; and providing international tax and legal advice related to the running of the inaugural European Games held in June 2015 in Baku, the 2016 Olympics in Rio de Janeiro, 2020 Olympics in Tokyo and the 2024 Olympic bid by Los Angeles.

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