Representation of a high net worth family whose stock holdings in a major consumer products company total close to $1 billion, the majority held in foreign trusts. The trusts were restructured to make potential distributions more tax efficient. The trust restructuring involved permitting distributions to the U.S. in the form of qualified dividends, taxable at a 20 percent rate versus the higher ordinary income tax rate. The impact of the throwback rules that apply to accumulated income which is distributed from a foreign trust to a U.S. beneficiary was also minimized.
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.