- Structured the $500 million sale of operations in Ireland, Spain, and The Netherlands on behalf of a multinational food and beverage company and defended an IRS audit.
- Represented a U.S. manufacturer with several acquisitions and restructurings over the course of 13 years, including a $2.5 billion acquisition of European operations.
- Represents a worldwide financier in connection with investments in 25 countries.
- Handled international restructurings responding to the Tax Cuts and Jobs Act of 2017, including the use of hybrid entities and instruments, OECD BEPS, and ATAD II.
- Handled numerous IRS audits at Exam and Appeals levels for more than 32 years.
- Worked on many international, technology-related arrangements, including the use of offshore licensing and R&D arrangements.
- Defending a $58 million foreign tax credit position relating to the allocation and apportionment of expenses before the IRS.
- Phone: +1 404 881 7481
- Email: email@example.com
Wherever global business objectives take his clients, Sam offers an innovative approach to complicated federal and international tax issues. Over the course of his 30-year career, Sam has worked on virtually all forms of cross-border investments.