Global Technology Firm’s Restructuring Yields Significant Tax Savings

Software Company

Assisted large technology and software company specializing in software services to global 1000 companies, with restructuring global operations to minimize worldwide tax on income from U.S. and foreign-source software sales. Restructuring yielded substantial global tax savings and deferral on U.S. recognition of the income, eventually repatriating the income at a 23.8 percent tax rate, versus 37 percent ordinary income tax at the U.S. federal level on all income as it was earned, onshore or offshore.

Related Practices
MORE EXPERIENCE
Experience
Representation of B piece and special servicer clients, handling in excess of $130billion in 2.0 CMBSsecuritizations.
Experience
Representation of an energy company in its $9.45 billion all-cash acquisition of another energy company, resulting in the creation of the largest utility holding company in the United States.
Experience
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...
VIEW MORE EXPERIENCE