WINSTON LEGAL GROUP

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, “2,689 Companies,” and Special Importation Regimes (e.g., FUNDAP)
  • Brazilian Tax Litigation Planning
  • 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. LLCs and other Tax Transparent Vehicles