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.,
- 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.