The Firm's tax attorneys regularly provide counsel to clients with cross-border business activities. Tax planning can reduce the cost of acquiring a target's foreign operations or it can facilitate a foreign acquiror's acquisition of a U.S. target. The Firm's tax attorneys work with tax counsel and advisors in foreign jurisdictions to develop structures that are tax efficient from both a U.S. and a foreign tax perspective.
Many of our LBO fund clients have recently established offices in Europe leading to an increase in the number of cross-border transactions in which we have become involved. For example, the Firm provided advice on U.S. tax issues with respect to KKR's acquisition of certain business units from Laporte plc, a U.K. specialty chemical company with significant operations in the U.S.
Many of the sophisticated transactions and financial products developed in the U.S. can be useful in similar situations abroad. However, foreign tax and regulatory concerns often make use of the identical transaction or product impractical or impossible in foreign jurisdictions. The tax department is involved in restructuring these transactions and products to meet restrictions in foreign jurisdictions and the specific concerns of foreign clients. Recent transactions include asset securitizations in Brazil, Turkey, Japan, Korea and Malaysia and cross-border leasing transactions involving a number of European countries such as Switzerland and the United Kingdom.