Foreign Mergers, Acquisitions, and Dispositions
Washington DC and Miami Attorneys
Castro & Co., we can structure and negotiate acquisitions and dispositions of foreign
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.