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Tax, International

Your business isn’t confined within one country’s border. Your tax obligations aren’t either. Work with tax attorneys familiar with the unique laws of numerous jurisdictions who partner with other law firms around the world to ensure your best possible tax position.

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Tax, International

Summary

Your business likely extends beyond the physical boundaries of your jurisdiction. We represent domestic and international corporations and unincorporated entities with complex international cross-border transactions and multinational agreements. Procopio’s International Tax attorneys are qualified in multiple jurisdictions, and as a founding member of LawExchange International and an active member of Meritas, we have access to knowledgeable and experienced legal representation around the world that provides you with diversified global support and insights.

  • Assist with the bilingual drafting and negotiating of commercial transactions, mergers and acquisitions, joint venture agreements and other foreign direct investment structures, lease agreements, distributorship agreements, supply agreements and general terms and condition contracts.
  • Conduct due diligence and planning and executing negotiated mergers and acquisitions, as well as in structuring joint ventures and other strategic alliances, including partnership agreements, licensing agreements, manufacturing and distribution arrangements or technology-sharing agreements.
  • Work directly with a team focused solely on the full range of public and private debt and equity vehicles and their investment activities.
  • Skilled in tax law, executive and corporate compensation, benefits planning and disputes with state and federal tax authorities—provide knowledgeable and tax-advantageous counseling, transactions and planning.
  • Assist multinational companies and domestic companies start or expand business in the US by developing strategic Intellectual Property (IP) plans.
  • Assist with trademark, copyright, domain name and trade dress infringement actions, commercial IP strategies, patent litigation, anti-counterfeiting and anti-piracy counseling, licensing and technology transfers, due diligence and nondisclosure, confidentiality and non-compete agreements.

Latin America

  • Advise U.S. and international investment funds regarding tax preferred structures for joint U.S.-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits.
  • Advise foreign financial institutions (non-U.S.), foreign entities and their advisors and employees regarding the application, strategic decisions and implementation of the federal tax law, Foreign Account Tax Compliance Act.
  • Represent international entertainers, many located in the Latin American region — including various Grammy Award winners — regarding tax planning considerations of their worldwide publishing, promotion, concerts, tax-exempt foundations, sales, and related activities.
  • Assist numerous U.S. developers (joint ventures, land and construction development) with Mexican and Latin American (e.g., Costa Rica and Guatemala) real estate acquisitions and development; structuring global operations, financing, equity investment, repatriation of funds and tax treaty benefits.
  • Represent various Mexican and Latin American, manufacturing, technology and agricultural companies with U.S. and worldwide joint venture, distribution and sales companies.
  • Assist multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with U.S. and Latin American individual and institutional investors.
  • Assist various multi-million dollar Mexican real estate land owners with U.S. joint venture real estate developments.

Asia

  • Negotiated a platform joint venture agreement with Morgan Stanley Real Estate Investment Funds on behalf of co-investor/managers for management, development, and investment in retail property located in the People’s Republic of China and India (venture size of $300 million).
  • Counsel clients in international project financing and access to capital market in Hong Kong, Taiwan and Mainland China.
  • Counsel clients in partnering negotiations, technology acquisition, licensing, joint research, development and outsourcing production and distribution relationships for clients in the U.S., China, and other countries.
  • Counsel clients in the greater Pacific Rim region in investments and doing business in the U.S.
  • Enforce actions on behalf of U.S. and international clients against IPR abuses in China.
  • Prosecute administrative and criminal enforcement actions against counterfeiters resulting in seizure of substantial quantities of counterfeits and criminal convictions of Chinese counterfeits. In one action, case was cited by the China Quality Brand Protection Committee as one of the top ten model cases of IPR enforcement in China for 2013-2014.
  • Enforce actions against IPR abuses on top Chinese Internet trade portals on behalf of clients with innovative, proprietary technology resulting in the removal of counterfeit products valued at over $12 million; success rate over 98% over an 18-month period.
  • Assist clients in the execution of their Global IPR enforcement strategy (administrative and judicial enforcement and raids and customs seizures against counterfeiters and infringers).

University of San Diego – Procopio International Tax Institute

Founded in 2004, the Procopio International Tax Institute at the University of San Diego School of Law was developed to educate and inform foreign individuals and international companies seeking to do business in the United States. With the goal of increasing access to international tax knowledge and promoting cross-border education and cooperation between tax attorneys, accountants, financial experts and other interested business and tax groups, the institute presents an annual conference focusing on various tax related topics relevant to its international audience. Learn more at USD-PITI.com.

 

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