Global Tax

Our clients look to us for guidance on a wide range of global tax issues. We advise corporations and their shareholders in connection with their offshore acquisitions and activities and in connection with international operations and acquisitions. We regularly counsel clients on the coordination of tax laws in multiple jurisdictions in order to develop and implement cross-jurisdictional tax planning, overall operational synergies, and worldwide tax minimization strategies.

Our tax lawyers advise on structuring cross-border acquisitions and dispositions, and on the formation and operation of international joint ventures and business alliances in order to evaluate and manage potential tax costs consistent with the underlying business objectives. We work with local tax advisors where necessary (we have an established network of international relationships) to devise optimal structures that integrate all relevant tax laws. We assist many clients with advance structuring designed to facilitate their organic growth internationally, as well as in connection with growth by acquisitions. This advice typically involves questions of choice of entity types, development of holding company structures, drafting and implementing necessary intercompany arrangements, and appropriate tax classification of entities.

Morrison & Foerster is well-known for its deep experience in technology transactions, and our tax lawyers frequently assist clients in the development and implementation of appropriate structures for the ownership, development, and exploitation of intellectual and other intangible property internationally, including compliance with the rapidly changing “substance” requirements around the globe. We also advise clients on the application of the new “digital taxation” rules that are being adopted by many countries, and on the interplay of these new laws with the existing treaty obligations of the taxing jurisdiction.

We have a market-leading practice advising government-linked investors such as sovereign wealth funds, public sector pension plans, central banks, and other state actors on complex global tax matters. Our preeminent position in this area is highlighted by our attorneys’ authorship of the leading treatise on the US taxation of foreign governmental entities.

We have a broad and deep knowledge of “supra-national” tax rules, such as those applicable in the European Union as well as all important OECD guidelines on global taxation. These guidelines, along with recent global tax changes in the United States, have reshaped the face of global tax planning. Our tax lawyers collaborate across jurisdictions to deliver results to clients that embody state-of-the-art solutions in a rapidly changing tax landscape.

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