Structuring & Evaluating Financial Products

Washington DC and Miami Tax Lawyers

Companies involved in financial products (on the development side or as potential purchasers) know that such products, designed correctly, can provide competitive returns and aid in risk management while also providing creative solutions to a variety of tax concerns. This has made financial products an area of dynamic growth, particularly in the international setting where their value is frequently enhanced through the use of hybrid entities and hybrid transactions ( i.e., entities and transactions that are characterized differently for U.S. and foreign tax purposes), as well as through the use of a variety of notional principal contracts, sale-repurchase “repos” agreements, and other features.

With the growth in this area, however, has come intense IRS and legislative scrutiny, thereby placing a premium on ensuring that the financial product is carefully designed from the outset.

Castro & Co. can assist clients in designing tax-advantaged financial products and in evaluating financial products designed by others. These products can be used for cross-border financing and achieve the U.S. tax benefits desired by the parties. We also are mindful of our duty to say “no” to ideas that do not work. Our Washington DC tax attorneys believe cautioning clients against strategies that do not work is as important as helping them devise strategies that do.

If you are structuring or evaluating cross-border financial products, here are some of the ways that Castro & Co. can help:

  • Evaluate existing financial product designs to determine whether they will accomplish U.S. tax objectives.
  • Advise on alternative designs to maximize US tax benefits and the likelihood of achieving them.
  • Prepare relevant transaction documents (e.g., partnership agreement, swap agreement and confirmation, etc.).
  • Prepare and file documents to organize appropriate U.S. entities (e.g., LLC formation).
  • Advise on the applicability of tax shelter registration, disclosure, and list maintenance requirements.

We not only serve those where our offices are located in Washington DC, Miami, Dallas, Orlando, but we also represent clients all over the world. Retain the experienced tax lawyers you need by calling (888) 595-5088 for a free evaluation.

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