Christopher J. Feldman

REPRESENTATIVE MATTERS

• Implementing a complex temporary onshoring of a large U.S. multinational's intellectual property into the U.S., including assessing tax implications in multiple jurisdictions and ensuring minimal operational changes.
• Assisting a U.S. multinational with a global legal entity rationalization. The U.S. multinational had grown organically through mergers and acquisitions, resulting in duplicative and redundant operations and entities in various jurisdictions. This restructuring involved a cross-section of legal, employment and tax issues in the local jurisdictions, requiring a comprehensive plan to leverage various tax-efficient mechanisms and regimes.
• Assisting a U.S. multinational with the integration of a multi-billion dollar global acquisition. This included designing and defending complex worldwide IP and operational integration initiatives, including C-Suite and audit committee discussions and auditor review.
• Representing a client in front of the U.S. and Ireland tax authorities related to mutual agreement procedures under the U.S.-Ireland Income Tax Treaty, to mitigate double taxation stemming from a dual-registered subsidiary.
• Representing a U.S. multinational in front of the German tax authorities related to withholding taxes due on intercompany license transactions involving novel issues of jurisdictional nexus.
• Assisting an international shipping company with its U.S. and international operating footprint and tax structure, including assessing the availability of beneficial worldwide tax regimes available for international shipping companies operating worldwide.
• Assisting global investors with the tax structuring of a U.S.-based private equity investment into a Mexican fintech company, including shareholder-level on-going and divestment tax considerations, as well as worldwide tax-efficient operational structuring for the Fintech company.