Non-US banking institutions, trust companies, fund administrators, investment managers and the like regarding compliance with the Foreign Account Tax Compliance Act (FACTA), application of so- called “UK FATCA”, and the Common Reporting Standard of the OECD
Non-United States trust companies with respect to their fiduciary and other planning needs,
particularly involving trusts where United States beneficiaries are either currently or expected to be within the pool of beneficiaries, including structuring or restructuring business and real estate interests in the United States
Non-United States financial institutions with respect to crafting investment products eligible for United States investors, registration before the Securities and Exchange Commission as registered investment advisers, and the development of investment products to protect non- United States persons from United States estate tax exposure
A foreign multinational corporation in connection with its acquisition of a large publicly traded US group of consolidated corporations where the foreign multinational was majority owned by a French billionaire family
A wealthy family in its tax-wise philanthropic activities, including charitable gifts aggregating as much as US$60 million in a single year.
Private equity fund and hedge fund managers with respect to their complex legal issues, including the structure and implementation of management-led buyout of multibillion-dollar funds and other restructurings, all with view to improve aggregate after-tax consequences to managers and their principals
Several real estate investment trusts (REITs) in the development of tax-sensitive acquisition programs, including creative techniques that minimize the adverse tax consequences to persons from whom they acquire real estate
Non-United States trust companies in the acquisition of operating businesses in the United States, including hotel management businesses and software concerns, or substantial real estate holdings for the benefit of their trust clients
REITs engaged in development joint ventures, including structuring the arrangement of the parties to minimize the application of excise taxes attributable to so-called prohibited transactions
Billionaire families with respect to "institutionalization" of their wealth over multiple generations and jurisdictions, including establishment of licensed trust companies based in offshore or domestic jurisdictions, dedicated to family trusts, family banks and related structures facilitating the clients' needs
A domestic group of companies in its purchase of companies from bankrupt corporate estates and the subsequent management of purchased assets with a view toward managing the use of sizeable net operating losses
A publicly traded New Zealand multinational in the disposition of certain manufacturing facilities and its subsequent relocation to more tax-efficient and business friendly jurisdictions, including China, South Africa and Hong Kong
Ultra-high-net-worth non-US families in their worldwide organizational and tax structures designed to reduce the incidence of worldwide income, capital, gift, estate and generation-skipping taxes, including the establishment of foreign trusts for the benefit of US family members
A large multinational luxury goods company in restructuring and disposition of its United Kingdom- and Geneva-based art and auction business
A Kenya-based charitable organization dedicated to the identification, documentation and preservation of prehistoric artistic imagery carved in rock throughout Niger, South Africa and the Northern Sahara desert
An island in the West Indies in its recent information treaty with the United States.
A European-based enterprise in the licensing of its trademarks and other intellectual property globally.
A US-based public company in connection with its expansion worldwide, principally through the acquisition of non-US enterprises engaged in similar industries.
Representation and establishment of an intricate web of European-based "group finance" operations, including planning for organizations established in jurisdictions with favorable tax treaties, with a view toward minimizing the imposition of worldwide taxation of the business operations of its affiliated organizations.
Chinese, Spanish and Czech multinationals in the restructuring of US operations for selling goods or licensing technology in the US, as well as representation of US manufacturers in establishing equity joint ventures in Ireland, Brazil and China.
A large privately held multinational group of foreign corporations in connection with the investment by US persons in shares of its stock, including the development of a structure designed to avoid classification as a "passive foreign investment company."
Private equity funds in acquisitions worldwide including in Brazil, Mexico, Germany, France and Korea.
Private equity funds organized in the Cayman Islands and the British Virgin Islands in acquisitions of US business operations.
Various entities before the Internal Revenue Service in private letter rulings related to REIT issues, characterization of contingent interest and spinoffs, as well as tax controversy matters related to contingent liability tax shelters and equipment leasing transactions.