Page 15 - Key Additional Legal Services for Vantage Data Centers Brochure

Corporate Tax
Key Additional Legal Services for Vantage Data Center
• Developing tax-efficient cross-border sales and
distribution, financing and licensing arrangements.
• Advising on the use of international tax treaties to minimize or eliminate international double taxation.
• Providing advice to non-U.S. investors regarding the acquisition, operation and disposition of U.S. real estate assets.
• Analysis of transfer pricing issues arising from related party cross-border transactions, including intercompany transfers of tangible and intangible property and service arrangements.
•Counseling employees and employers regarding tax and withholding issues associated with international employment.
• Representing clients before the IRS and in federal courts with respect to a wide variety of international tax issues.
Keith Gercken
Partner / Corporate & International Tax
San Francisco kgercken@sheppardmullin.com 415.774.3207
Our Tax attorneys use innovative tax planning with an emphasis on practical solutions to provide sophisticated legal advice to clients in a variety of industries. We specialize in tax-efficient structuring of transactions and the planning and financing of business affairs. We pride ourselves on our depth and breadth of experience, our understanding of market trends and our commitment to our clients. We also can assist Vantage Data Centers in structuring real estate transactions and planning business affairs in order to reduce income, sales, transfer, property and other taxes
International Tax Planning
We can also provide comprehensive advice and technical expertise in strategic tax planning relating to the international tax aspects of your business operations and portfolio investment activity. We have extensive experience in Latin American, Canadian, Asian and European markets, and leverage our core experience in U.S. tax law with an excellent network of local counsel in a wide range of foreign jurisdictions to enable our clients to achieve their business objectives while minimizing their worldwide tax risks and exposure. Our international tax practice provides a broad range of services, including:
• Advising on the selection of appropriate onshore and offshore legal structures for the conduct of foreign operations and international joint ventures, including advice relating to the optimal classification of U.S. and foreign business entities for U.S. tax purposes.
• Planning for mergers, acquisitions, dispositions, restructuring and reorganizations involving U.S. and foreign companies.
• Advising on the application of U.S. foreign tax credit rules and “anti-deferral” regimes such as those relating to “controlled foreign corporations” and “passive foreign investment companies” including the new global intangible low income tax rules.
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• Practice includes all areas of business income taxation, with emphasis on corporate and partnership taxation and international transactions.
• Advises corporate and individual clients on the U.S. federal and international tax consequences of a wide range of transactions, including taxable and tax- free mergers and acquisitions; partnerships and joint ventures; the formation and operation of equity funds; finance transactions; tax-free exchanges; international licensing; foreign operations (including cross-border joint ventures between U.S. and non-U.S. partners); and inbound investment into the United States by non-U.S. investors.