WINSTON LEGAL GROUP LLC

INTERNATIONAL AND CORPORATE TAX PLANNING INCLUDING:

  • Tax Efficient Cross-Border Structuring and Cash Flow Management
  • Manufacturing and Distribution of Goods (Supply Chain Structuring), Including Buy/Sell and Licensing Models
  • Cross Border Provision of Services, Including Outsourcing Models
  • ​​CFC, GILTI/NCTI, FDII/FDDEI, BEAT, and PTEP Issues
  • Brazilian Taxation and Special Importation Regimes
  • Tax-Based FCPA and Fraud Investigations
  • Tax Treaty Planning and Interpretation​​​​​
  • Value Added Tax (VAT) Management and Planning
  • Latin American Customs and Importation Regimes (MERCOSUR and ALADI) 
  • Latin American Free Trade Zone Regimes
  • Initial “Choice of Entity” and Corporate Governance Planning
  • Export and Currency Exchange Controls (e.g., Venezuela and Brazil) Financing and Licensing Structures
  • Acquisitions, Dispositions, and Mergers
  • International Tax Planning with U.S. Limited Liability Companies (LLCs) and other Tax Transparent Vehicles