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.