Belize-Based Business Restructures to Reduce Tax Liability


Restructured entities to avoid currency restrictions in Belize to facilitate partial sale of a domestic beer company to a global brand and distributor. Advised on minimizing U.S. tax resulting from the restructuring and sale to defer U.S. recognition of the gain from the sale. Additional restructuring ensured the availability of foreign tax credits, which was unclear given the unusual nature of the Belize tax system and the recency and lack of guidance on the global intangible high-taxed income (GILTI) provisions under U.S. law.

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