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
• Brazilian ICMS, IPI, ISS, PIS/COFINS, CIDE, II, FIPs, IOF, and Special Importation Regimes (e.g., FUNDAP)
• Brazilian Tax Litigation Planning
• 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

WINSTON LEGAL GROUP