Navigating Complex International Corporate Restructuring

Challenge

A multinational technology corporation sought our expertise to restructure its global operations through a holding company structure and merger with a competitor. The challenge involved integrating numerous unrelated entities across multiple jurisdictions, including several foreign entities, while optimizing tax efficiency and ensuring regulatory compliance.

Approach

Our corporate restructuring team, comprising international tax specialists, corporate governance experts, and M&A attorneys, developed a comprehensive strategy:

• Designed a tax-efficient holding company structure leveraging specialized tax strategies and corporate structures
• Navigated complex cross-border regulations, including FATCA, CFC rules, and local corporate laws
• Drafted and negotiated intricate intercompany agreements, including contribution arrangements and IP licensing agreements
• Coordinated with local counsel to ensure compliance with local corporate, labor, and tax laws
• Implemented a robust corporate governance framework to manage the new multinational structure effectively

Result

We successfully integrated all entities into a streamlined structure, achieving significant benefits for our client:

• Enhanced global compliance and risk management through centralized oversight