Global Connectivity.
In our increasingly connected global marketplace, almost every action by a corporation has a cross-border component. Clients, including multinational corporations, major financial institutions, investment funds and their sponsors, foreign sovereigns and individuals, turn to Milbank's International Tax Group attorneys for their proficiency in advising on a wide variety of tax matters, including:
- Cross-border acquisitions, reorganizations and joint ventures
- Inbound and outbound investments
- International capital market transactions
- Cross-border derivatives and innovative financial products
- Cross-border investment fund and investment management structures
- Tax-efficient use of offshore trusts and corporate structures for high-net-worth individuals and multinational families.
fully integrated structuring capability
In the corporate arena, our tax expertise in M&A and private equity transactions in multiple jurisdictions provides our international investment banking, corporate and private equity clients with coordinated and fully integrated structuring capability. Our International Tax lawyers provide structural solutions to conflicting tax, other legal, financial and commercial issues and combine specialized technical skills with the capacity to negotiate and execute such solutions. We have advised on some of the most significant recent US-European corporate combinations and regularly provide tax advice on European acquisitions to many prominent private equity funds and sponsors.
financial products. structured finance. derivative transactions.
We have particular expertise in the development of new financial products, structured finance and derivative transactions. In addition to working on domestic and foreign debt and equity securities offerings, our team works with clients on the development and execution of innovative financial solutions to fit particular client needs, including the development of financial products that produce tax benefits in multiple jurisdictions.
In structured finance, the Tax team helps investment banking clients to develop tax- and balance sheet-efficient capital transactions in the US and across many European jurisdictions. In the field of project finance, we structure tax-efficient consortia (through a variety of corporate, partnership and hybrid mechanisms) that enhance the yields to debt and equity providers, taking into account the tax treatment of the transaction across different jurisdictions, to fund a range of underlying, single-asset, pool, private finance initiatives and privatization projects.
Transportation Finance
Our International Tax lawyers are an important part of our market-leading Transportation Finance Group and regularly represent carriers, leasing companies and credit providers in the cross-border leasing of aircraft and the use of the lease-to-service contract structure. We have extensive experience in designing investment structures to facilitate investment by offshore funds and investors in aviation leasing businesses and securitizations of leased assets, where familiarity with tax treaties, withholding requirements and other international tax consequences is paramount.
private investment funds
Our International Tax team also regularly advises private investment funds in the key areas of fund formation, complex financial transactions (including derivatives and other investment vehicles that private investment funds use to tailor investment decisions to the tax positions of their investors) and the workout or restructuring of an investment so that a fund can maximize the after-tax returns to its investors. This experience includes advising on investments in evolving asset classes like life settlements and litigation settlements.
Global qualifications
Attorneys in our International Tax Group are qualified to practice US, German and UK tax law, and we also work with a global network of trusted tax advisors in other jurisdictions.