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Bracewell attorneys have experience in cross-border in-bound and out-bound investments, including the formation of holding companies to facilitate acquisitions, the formation of international joint ventures and the qualification under tax treaties for a zero or reduced rate of withholding tax on the repatriation of profits. Bracewell attorneys are able to recommend the optimal strategies involving corporate structure and capitalization. The tax treatment of dividends, interest, royalties, and capital gains under tax treaties is a critical aspect of our practice. Bracewell advises on the Foreign Investment in US Real Property Tax Act (FIRPTA) and the Foreign Account Tax Compliance Act (FATCA) and its implications for cross-border investments, including real estate, oil and gas and project finance.

Our advice begins with tax planning, continues through the implementation and conclusion of the transaction, and remains through audit or examination. Our experience covers the energy and technology industries and includes taxes that are particular to those industries such as a foreign petroleum tax as well as generally applicable taxes such as corporate income taxes and transactional taxes such as value added tax, sales tax and property taxes. Our professionals are versed in transfer pricing rules, import/export rules and valuation guidelines.

Recent Representations

  •  Advised a Spanish company with respect to the purchase of a US target
  • Advised a foreign private equity fund on US oil and gas investments, including FIRPTA issues
  • Advised a foreign family investment office with respect to setting up a US advisory office and US investment fund
  • Advised a foreign pension fund on US oil and gas investments
  • Advised a US-based multinational with respect to structuring holding companies and operating subsidiaries throughout the world
  • Advised a foreign private equity fund and family investment office with respect to dispositions of US investments
  • Advised borrowers and lenders with respect to FATCA