International Tax & Tax Planning | White & Case
International Tax & Tax Planning

Tax

In the ever-changing economic environment, tax regimes similarly evolve. Today, governmental efforts to increase or maintain tax revenue levels pose new and difficult challenges for tax planning and dispute resolution.

Globalization also creates complex tax issues requiring companies to deepen their knowledge of national tax laws and treaties. Given our global tax presence, clients seek our advice on reaching their business goals in light of the multiplicity of national tax laws and the cross-border nature of today's tax issues.

Tax efficiency, risk reduction, avoidance of tax controversy, and the successful resolution of an unavoidable dispute are goals that can best be met where the tax team possesses strong national and cross-border experience. We effectively and efficiently partner with our clients to meet these goals.

Tax services and capabilities

Whether the tax issues are focused on a single country or cross-border, involve planning for tax efficiency or require resolution of a civil or criminal tax controversy or investigation, our global Tax Group can provide appropriate solutions.

We understand the business and legal intricacies of international taxation. Our group is recognized for its forward-thinking approach on tax matters as well as precedent-setting firsts in the tax field globally in terms of tax planning, transfer pricing, tax controversy, post-acquisition integration, investigative matters, and tax legislative initiatives.

 

AWARDS

"Provides valuable expertise on cross-border tax matters thanks to an impressive spread of offices throughout Asia, the USA, CEE and Western Europe. Services blue-chip corporations, financial institutions, investment funds and sovereign wealth funds on both transactional and standalone tax matters."
Chambers Global 2013

Chambers & Partners Awards For Tax Include:
Chambers Global 2014 (Global, France, Poland, Russia, United States)
Chambers Asia-Pacific 2014 (Japan)
Chambers Europe 2014 (Europe-wide, Czech Republic, France, Hungary, Poland, Russia)
Chambers USA 2014 (Nationwide tax controversy, New York, Florida)

The Legal 500 Awards For Tax Include:
The Legal 500 – EMEA 2014 (Czech Republic, France, Germany, Hungary, Poland, Russia)
The Legal 500 – United States 2014 (International Tax, Tax Controversy, Domestic Tax East Coast)
The Legal 500 – Japan 2014

Other Notable Awards For Tax Include:
US News/Best Lawyers 2015 top tier ranking nationally and in Washington, DC for tax litigation, New York and Miami for tax.
Euromoney's Guide to the World's Leading Transfer Pricing Advisors recognize members of White & Case's global tax team.

Tax planning and transactional
Tax advice on US$20 billion joint venture with Dow Chemical on Saudi chemicals complex
Lawyers from multiple jurisdictions and practices, including Tax, provided Saudi Aramco with advice on its joint venture with the Dow Chemical Company to build and operate a US$20 billion world-scale integrated chemicals complex in Saudi Arabia.

Tax advice helps facilitate US$13.5 billion healthcare acquisition
In a major acquisition, the acquiring company needed astute tax advice to facilitate the deal. Our tax team provided principal tax advice to Zimmer Holdings Inc., a world leader in musculoskeletal health solutions, in its US$13.5 billion acquisition of Biomet, Inc., one of the world's leading medical device manufacturers. 

Cross-border tax issues resolved in Chinese acquisition of US company
We leveraged our knowledge of US and China tax laws as well as our cross-practice strength in advising Shenzhen Pharmaceutical Co., Ltd., a public Chinese company, and its US subsidiary, Hepalink USA Inc., in its acquisition of Scientific Protein, LLC, a leading global manufacturer and supplier of active pharmaceutical ingredients. This transaction is one of the few acquisitions by a public Chinese company of a US privately-held target.

Multijurisdictional tax structuring advice provided on sale by world-leading software company
When Avast Software, a leading antivirus company, and a selling shareholder consortium needed advice on the sale of a significant minority stake to CVC Capital Partners, a private equity firm, they turned to White & Case. The team knew Avast and its needs, and also understood the demands of private equity sponsors. Close cooperation throughout by the tax and transaction teams helped make this a success.

Tax controversy
Given the breadth of our international footprint, successfully resolving tax disputes for multinational clients is the focus of our tax controversy practice. Whether a dispute is anticipated, is already at the audit or administrative settlement stage, or has progressed to encompass alternative dispute resolution techniques or litigation, we work closely with our clients to develop the most effective and creative solutions. We also help clients assess their global tax risk and work with them to develop strategies for mitigating that risk.

Funds
Our tax lawyers work closely with, and as a part of, our investment funds global industry group in helping private investment fund sponsors, fiduciaries and institutional investors in existing and emerging markets achieve their particular tax and investment objectives. Our clients include established and emerging private fund sponsors around the world, as well as alternative asset groups, international financial institutions, sovereign wealth funds and other institutional investors.

Transfer pricing
Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be addressed. Our team of tax controversy and transfer pricing lawyers possess these attributes and appear regularly before all levels of domestic and foreign tax authorities and competent authorities. Our international breadth affords us the best opportunity to take a bilateral or multilateral approach to resolving disputes, including through the use of Advance Pricing Agreements, and we frequently work with the competent authorities in domestic jurisdictions and abroad to obtain the best results for our clients.

Post-acquisition integration
Once a global acquisition is completed, the company must then integrate the acquired business with its legacy business. Unsuccessful integration is the leading cause of failed acquisitions. We advise on all aspects of global post-acquisition integration projects: from international tax planning – to designing the combined company's go-forward corporate, labor, intellectual property, real estate, supply chain and commercial structure – to executing all integration transactions on a global basis. Our team of tax lawyers works closely with our lawyers in other disciplines to provide clients a single solution for implementing global integration projects effectively and efficiently. We also devise solutions for all types of internal restructurings, including establishing holding company structures, and restructuring a corporate group in anticipation of a spin-off or sale of a global division or business line.

Private equity
We regularly represent a wide variety of private equity firms on a broad range of tax issues. In particular, we advise on the tax aspects of the acquisition and disposition of portfolio companies, coordinating US and non-US tax aspects of cross-border transactions. We also represent the portfolio companies with respect to add-on acquisitions and ongoing tax advice.

Private clients
We advise high-net-worth individuals and families in all aspects of estate planning, estate and trust administration, multigenerational wealth transfer planning, income taxation, estate and gift taxation, the formation and administration of tax-exempt charitable entities, and prenuptial and post-nuptial planning. Given our global reach, we typically work with non-US individuals to minimize the tax consequences of moving to the US and investing in the US. In addition, we often advise US individuals on the increasing complex US tax and reporting requirements imposed on those who own accounts and assets abroad. Another aspect of our practice focuses on complex estate-related litigation, including in the multijurisdictional context.

Tax
About

In the ever-changing economic environment, tax regimes similarly evolve. Today, governmental efforts to increase or maintain tax revenue levels pose new and difficult challenges for tax planning and dispute resolution.

Globalization also creates complex tax issues requiring companies to deepen their knowledge of national tax laws and treaties. Given our global tax presence, clients seek our advice on reaching their business goals in light of the multiplicity of national tax laws and the cross-border nature of today's tax issues.

Tax efficiency, risk reduction, avoidance of tax controversy, and the successful resolution of an unavoidable dispute are goals that can best be met where the tax team possesses strong national and cross-border experience. We effectively and efficiently partner with our clients to meet these goals.

Tax services and capabilities

Whether the tax issues are focused on a single country or cross-border, involve planning for tax efficiency or require resolution of a civil or criminal tax controversy or investigation, our global Tax Group can provide appropriate solutions.

We understand the business and legal intricacies of international taxation. Our group is recognized for its forward-thinking approach on tax matters as well as precedent-setting firsts in the tax field globally in terms of tax planning, transfer pricing, tax controversy, post-acquisition integration, investigative matters, and tax legislative initiatives.

 

AWARDS

"Provides valuable expertise on cross-border tax matters thanks to an impressive spread of offices throughout Asia, the USA, CEE and Western Europe. Services blue-chip corporations, financial institutions, investment funds and sovereign wealth funds on both transactional and standalone tax matters."
Chambers Global 2013

Chambers & Partners Awards For Tax Include:
Chambers Global 2014 (Global, France, Poland, Russia, United States)
Chambers Asia-Pacific 2014 (Japan)
Chambers Europe 2014 (Europe-wide, Czech Republic, France, Hungary, Poland, Russia)
Chambers USA 2014 (Nationwide tax controversy, New York, Florida)

The Legal 500 Awards For Tax Include:
The Legal 500 – EMEA 2014 (Czech Republic, France, Germany, Hungary, Poland, Russia)
The Legal 500 – United States 2014 (International Tax, Tax Controversy, Domestic Tax East Coast)
The Legal 500 – Japan 2014

Other Notable Awards For Tax Include:
US News/Best Lawyers 2015 top tier ranking nationally and in Washington, DC for tax litigation, New York and Miami for tax.
Euromoney's Guide to the World's Leading Transfer Pricing Advisors recognize members of White & Case's global tax team.

Experience

Tax planning and transactional
Tax advice on US$20 billion joint venture with Dow Chemical on Saudi chemicals complex
Lawyers from multiple jurisdictions and practices, including Tax, provided Saudi Aramco with advice on its joint venture with the Dow Chemical Company to build and operate a US$20 billion world-scale integrated chemicals complex in Saudi Arabia.

Tax advice helps facilitate US$13.5 billion healthcare acquisition
In a major acquisition, the acquiring company needed astute tax advice to facilitate the deal. Our tax team provided principal tax advice to Zimmer Holdings Inc., a world leader in musculoskeletal health solutions, in its US$13.5 billion acquisition of Biomet, Inc., one of the world's leading medical device manufacturers. 

Cross-border tax issues resolved in Chinese acquisition of US company
We leveraged our knowledge of US and China tax laws as well as our cross-practice strength in advising Shenzhen Pharmaceutical Co., Ltd., a public Chinese company, and its US subsidiary, Hepalink USA Inc., in its acquisition of Scientific Protein, LLC, a leading global manufacturer and supplier of active pharmaceutical ingredients. This transaction is one of the few acquisitions by a public Chinese company of a US privately-held target.

Multijurisdictional tax structuring advice provided on sale by world-leading software company
When Avast Software, a leading antivirus company, and a selling shareholder consortium needed advice on the sale of a significant minority stake to CVC Capital Partners, a private equity firm, they turned to White & Case. The team knew Avast and its needs, and also understood the demands of private equity sponsors. Close cooperation throughout by the tax and transaction teams helped make this a success.

Tax controversy
Given the breadth of our international footprint, successfully resolving tax disputes for multinational clients is the focus of our tax controversy practice. Whether a dispute is anticipated, is already at the audit or administrative settlement stage, or has progressed to encompass alternative dispute resolution techniques or litigation, we work closely with our clients to develop the most effective and creative solutions. We also help clients assess their global tax risk and work with them to develop strategies for mitigating that risk.

Funds
Our tax lawyers work closely with, and as a part of, our investment funds global industry group in helping private investment fund sponsors, fiduciaries and institutional investors in existing and emerging markets achieve their particular tax and investment objectives. Our clients include established and emerging private fund sponsors around the world, as well as alternative asset groups, international financial institutions, sovereign wealth funds and other institutional investors.

Transfer pricing
Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be addressed. Our team of tax controversy and transfer pricing lawyers possess these attributes and appear regularly before all levels of domestic and foreign tax authorities and competent authorities. Our international breadth affords us the best opportunity to take a bilateral or multilateral approach to resolving disputes, including through the use of Advance Pricing Agreements, and we frequently work with the competent authorities in domestic jurisdictions and abroad to obtain the best results for our clients.

Post-acquisition integration
Once a global acquisition is completed, the company must then integrate the acquired business with its legacy business. Unsuccessful integration is the leading cause of failed acquisitions. We advise on all aspects of global post-acquisition integration projects: from international tax planning – to designing the combined company's go-forward corporate, labor, intellectual property, real estate, supply chain and commercial structure – to executing all integration transactions on a global basis. Our team of tax lawyers works closely with our lawyers in other disciplines to provide clients a single solution for implementing global integration projects effectively and efficiently. We also devise solutions for all types of internal restructurings, including establishing holding company structures, and restructuring a corporate group in anticipation of a spin-off or sale of a global division or business line.

Private equity
We regularly represent a wide variety of private equity firms on a broad range of tax issues. In particular, we advise on the tax aspects of the acquisition and disposition of portfolio companies, coordinating US and non-US tax aspects of cross-border transactions. We also represent the portfolio companies with respect to add-on acquisitions and ongoing tax advice.

Private clients
We advise high-net-worth individuals and families in all aspects of estate planning, estate and trust administration, multigenerational wealth transfer planning, income taxation, estate and gift taxation, the formation and administration of tax-exempt charitable entities, and prenuptial and post-nuptial planning. Given our global reach, we typically work with non-US individuals to minimize the tax consequences of moving to the US and investing in the US. In addition, we often advise US individuals on the increasing complex US tax and reporting requirements imposed on those who own accounts and assets abroad. Another aspect of our practice focuses on complex estate-related litigation, including in the multijurisdictional context.