U.S. Tax Reporting and Withholding  
  Qualified Intermediary ("QI") Advice  
  Tax Advice and Planning  
  Cross-Border Financial Structures  
  Collective Investment Vehicles ("CIVs")  
  Audit and Appellate Controversies  
  Tax Litigation  
  Rulings and Regulatory Lobbying  
  Alternative Dispute Resolution  
  Expert Witness/Litigation Support Services  
  Advice for Governments  

Cross-Border Financial Structures

We have developed or advised on cross-border financial structures over the last 15 years that very significantly reduce a borrower’s net cost of capital. The amounts financed using these structures exceed $50 billion dollars.

Each financing is developed “organically,” i.e., each must flow from the needs of the business in question. We begin by analyzing the business’ financing needs, then identify the most efficient structure, document the transaction, and assist with on-going compliance obligations. Tax authorities in the United States, United Kingdom, Canada and the Netherlands have audited these structures as part of customary tax compliance examinations and have not objected to or challenged any of them.


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