International Tax Planning

Tax lawyer Andrew L. Jones addresses corporate clients’ international tax planning matters from the dual perspectives of tax law and business law. Working with an attorney whose knowledge spans both fields ensures that a corporation avoids the unwelcome surprise of a great business opportunity wrecked by adverse tax consequences – or a tax-optimized deal that doesn’t meet business realities. Andrew’s holistic approach to corporate tax practice provides clients tailored advice and compliance on both day-to-day operations and mergers and acquisitions.

Representative Matters

US subsidiary of multinational IT outsourcing provider. Minimized tax exposure on multi-million dollar inter-company loans by providing structuring guidance to avoid re-characterization of payments as constructive dividends.

US technology services firm. Performed research and development tax credit analysis utilizinged firm’s internal documentation to create an analytical memo sufficient to satisfy an auditor’s second-round request for acceptable documentation.

Australian energy company. Provided executive guidance on tax consequences of exit from US technology investment by stock sale of US subsidiary or by US subsidiary’s sale of interest in partnership.

US online video firm. Provided company principals with small business corporation stock tax incentive overview.

US subsidiary of multinational IT outsourcing provider. Provided executives with options for stock-based employee retention options, including stock grants, employee stock options, incentive stock options (ISOs), non-qualified stock options (NQSOs or NSOs), and provided overview of valuation models applicable to valuing such options under Financial Accounting Standards Board’s FAS 123R.

US subsidiary of German medical supply manufacturer. Minimized client exposure to taxes and penalties arising from improper worker classification through contemporaneous documentation of grounds for relief under Section 530 of the Revenue Act of 1978.