U.S. Tax Reform Law Spurs Business Restructuring Opportunities

International Gaming Company

Restructured company’s international operations, which include locations such as South Africa, Poland, Egypt, Malaysia, Spain, and Switzerland, in response to U.S. tax reform to obtain U.S. deferral of offshore high-taxed global intangible high-taxed income (GILTI) and converting such income into "Subpart F income" that is eligible for special treatment under the "high-tax exception." Utilizing this structure also reduced the company's global effective tax rate by more than 20 percentage points.

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Handled the sale of over 2,000 REOs, with aggregate purchase prices in the billions of dollars, through both the negotiation and closing of individual sales and the structuring and sale by auction of multiple properties. The largest was approximately $216 million, which was the sale of a major hotel...