Structuring Private Equity for GILTI and Subpart F: Minimizing Tax for CFCs Under Section 951A, Final Regulations

Mr. Burstein has more than 13 years of experience providing international tax services to clients in a wide range of industries, including technology and life sciences, real estate, and consumer products. He has specific expertise in advising U.S. multinational companies and private equity firms on cross-border transactions, including cash repatriation planning, foreign tax credit analysis, global effective tax rate planning, and U.S. anti-deferral rules. Mr. Burstein also provides tax services to inbound investors, including acquisition structuring, permanent establishment analysis, and withholding rules. Additionally, Mr. Burstein assists companies and individuals with any required international tax reporting as part of their annual tax return filings and international tax components of annual financial statements. He has also guided U.S. companies and individuals in understanding the international tax components of the tax reform legislation passed in 2017.

Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients in a wide range of industries, as well as individuals and publicly traded companies. He has extensive experience working with multinational corporate clients on consulting and compliance projects, including global business model optimization and restructuring projects from the design and feasibility stage through implementation. He also has expertise in U.S. tax issues relating to both inbound and outbound investments, as well as navigating the increasingly complex network of reporting, disclosure, and withholding requirements arising from doing business in a global economy.

Mr. Rokoff has more than 35 years of experience in global and U.S. tax matters, helping clients ensure maximum financial benefit and optimum tax treatment. He has extensive experience in advising fund sponsors, investment advisors and investors in identifying and implementing tax-efficient structures worldwide to enhance after-tax yield for the investors and advisors. Mr. Rokoff has structured investments for U.S. and non-U.S. investors across a broad base of asset classes including real estate, debt and equities, operating businesses and alternative investments. In addition, he works with private equity funds and regulated investment companies that are active in the insurance sector and regularly advise them on their investments and ongoing operations.