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.

Related Topics
Related Practices
MORE EXPERIENCE
Experience
Representation of equity investor in its successful bid for the deployment of the Red Compartida wholesale broadband network, an approximately $7 billion public-private partnership with the Mexican Secretariat of Communications and Transportation.
Experience
Structured and negotiated license and royalty arrangements in Europe and Central and South America.
VIEW MORE EXPERIENCE