Foreign Mergers, Acquisitions, and Dispositions

Washington DC and Miami Attorneys

At Castro & Co., we can structure and negotiate acquisitions and dispositions of foreign companies; planning for the most tax-efficient structures from both U.S. and international business and tax viewpoints.

Issues may include stock versus asset purchases, whether to make a section 338 election to treat a stock transactions as an asset transaction, synthetic 338 “check-and-sell” arrangements, whether to effectuate a pre-sale income repatriation through a section 956 U.S. Property Investment to benefit from any possible indirect foreign tax credits, whether the acquired entity should be structured as a first-tier U.S.-owned foreign subsidiary or a lower-tier foreign-owned subsidiary, whether to utilize a leveraged holding company for an acquisition to reduce foreign taxes and maximize cash flow flexibility, and business entity choice.

Retain a knowledgeable tax lawyer from Castro & Co. by calling (888) 595-5088 for your free evaluation! We have offices in Washington DC, Miami, Dallas, and Orlando, but we represent clients all over the world.‚Äč

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