In the complex world of tax, our role is simple: to serve as an extension of your business. At Dentons, our value comes from seeing your business as you do and collaborating with you every step of the way. Together, we will develop and implement a plan based on your needs and aspirations—one that proactively identifies creative, integrated commercial tax-saving solutions.
When you engage Dentons for tax services, you’re getting an interdisciplinary team that understands how tax law meshes with other areas of the law—corporate, real estate and litigation, to name a few. You are drawing from a focused team with years of experience in your industry. It’s a cross-border, multijurisdictional group that seamlessly mixes local knowledge with the right resources in order for your business to stay nimble and robust.
Whether excise or extra-jurisdictional, taxes will always impact your business. As regulations and issues shift and evolve, Dentons will work with you to ensure you stay ahead—with your goals as our guide.
Dentons’ comprehensive tax services include experience in worldwide jurisdictions, as well as in matters relating to individuals and private companies, multinational companies, listed companies, blue-chips, partnerships and other transparent entities, tax-advantaged investing and more.
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- Bridgewater Systems Corporation: Advising on its acquisition by Amdocs Limited for C$211 million. Amdocs is the market leader in customer experience systems innovation. Bridgewater is the leader in intelligent broadband controls and provides pre-integrated solutions for mobile and converged operators to transform their networks, optimize mobile data growth and innovate with new services.
- Capital Power Income L.P.: Advising on its CA$1.1 billion acquisition by Atlantic Power Corporation.
- Global healthcare leader: Advising in respect to structuring a promotion arrangement with one of the largest Russian distributors of its products, development of respective contracts between the parties; various antitrust aspects of promotion and distribution of its products in Russia, including development of its commercial policy; clinical trial agreements; product registration; combined marketing and promotion of complimentary products produced by the client and a third party; exclusion of a product from the Register of Vital and Essential Drugs; use of personal data by medical representatives; due diligence criteria for a selection of distributors; and inaccurate and misleading marketing and promotional materials of a competing product.
- Grant Forest Products Inc.: Advising on the CCAA and US Bankruptcy Court approved acquisition of its oriented strand board facilities in Ontario and South Carolina, US by Georgia-Pacific LLC for $400 million. The process for the acquisition involved a series of court and regulatory approvals on both sides of the border, and included approval from both Canadian and US courts, the Canadian Competition Bureau, the US Federal Trade Commission and Investment Canada.
- Polish, Luxembourg and Dutch tax: Advising on the Polish, Luxembourgian and Dutch tax aspects of setting up investment funds to operate on the Polish real estate market. International tax structuring allowing for tax-efficient conversion of tax into the target structure and obtaining relevant tax rulings in Poland and the Netherlands. The advice on the transaction addressed tax, legal and business goals of the client, taking into consideration the old structure and potential future changes to applicable laws.
- Sasol Petroleum International: Advising on the C$1.05 billion acquisition of a 50 percent working interest in Talisman Energy Inc.’s (Talisman) Farrell Creek shale gas assets in the Montney Basin area of northeastern British Columbia, a subsequent transaction with Talisman for similar consideration of C$1.05 billion, which expanded Sasol’s gas reserves in the area, with a view to the further development of a gas-to-liquids plant to be located in Canada and to serve the North American liquid fuels markets.
- Spanish engineering consortium operating: Advising on a joint venture project related to the development of a nuclear power reactor located in France. Our tax teams in Spain and France advised the client on the tax treatment of the joint venture, on the establishment of a branch in France, and on the tax implications for the seconded employees. We successfully dealt with complex CIT liability, VAT, PIT, a double tax treaty between France and Spain, and sophisticated permanent establishment issues. We helped the client to reduce tax burdens by avoiding paying double taxation in France and Spain. We also helped the client organize the arrangements between the members of the consortium.
- Strategic Hotels & Resorts: Advising a real estate investment trust traded on the NYSE, and one of the largest owners and asset managers of the highest quality portfolio of luxury hotels and resorts in the world, on its $235 million acquisition and immediate resale of Champs-Elysées' Marriott Hotel and simultaneously on the tax audit which was initiated by the French tax authorities. Due to the audit and the fact that the tax authorities questioned most of the client’s tax transfers, there was a very high risk that the acquisition and resale would not go through; however, our tax team demonstrated its expertise and effectiveness by securing significant tax savings for the group and minimizing the risks arising from the audit. The transaction took place within a very short period of time, and the innovative cross-border tax structuring designed by our experts involved four jurisdictions.
- US Gold Corporation: Advising on its acquisition of Minera Andes Inc. by plan of arrangement under the Business Corporations Act (Alberta) with a transaction value at the time of closing of approximately C$1.4 billion for the combined company, which was renamed McEwen Mining Inc. This transaction was highlighted as a “Big Deal” in LEXPERT's April 2012 issue.
- WestLB: Advising a major German bank on a spin-off transaction concerning a bank with €40 billion in assets and 400 employees and involving a €1 billion share capital increase half-contributed by a bank which we advised on tax and corporate structuring aspects. The spin-off will act as a service unit for the savings banks (Sparkassen) located in the state of Nordrhein-Westfalen. Hessische Landesbank will take over the shares in the spin-off. In order to fund the transaction, Hessische Landesbank went through an increase in share capital amounting to €1 billion. Part of the capital increase (€500 million) was contributed by Deutscher Sparkassen und Giroverband (DSGV), who we advised on the tax and corporate structuring of the transaction.
April 4, 2014
August 16, 2013
The Internal Revenue Service recently issued guidance on the timing of the deduction for annual bonuses for top executives of public companies, and, separately, issued regulations clarifying limitations on postponing income tax on compensation under tax code Section 83. These, together with litigation involving employment tax withholding have given rise to a renewed examination of employers' tax processes and plan language.
In this article, Dentons Pension, Benefits and Executive Compensation partner Pamela Baker addresses these developments affecting US executive compensation. Read more
June 14, 2013
The awards acknowledge the excellence of our tax group both collectively and individually. Read more
The 2013 edition of The Legal 500 US recognizes 15 Dentons practices and 42 lawyers, representing a more than 50 percent increase in total rankings in the past year. Recognition for the Firm includes "seamless extensions of clients’ teams;" "exemplary strategic and tactical leadership;" and "far above other firms, both in technical strengths and business experience." Read more
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April 21, 2015
April 20, 2015
In the wake of the release of the much-anticipated 2015 Federal Budget, the Tax Group at Dentons has prepared a Special Report which provides a detailed analysis and concise summary of the changes featured in the Budget. The Report also highlights the potential implications for businesses and investments in Canada. Read more
April 7, 2015
Dentons’ Russian Tax and Customs practice would like to remind you that less than one month remains to the deadline for filing 2014 tax returns. Individuals required to independently declare and pay personal income tax must file a 3-NDFL tax return form with their local tax authority by April 30, 2015. The tax payable according to the return must generally be paid on or before July 15, 2015. What personal income must be declared? Read more
The IRS and Treasury Department recently issued regulations that provide rules for making a “Section 336(e) election.” This election is a relatively new tax-planning tool to achieve a step-up in the tax basis of the target corporation’s assets for income tax purposes where an asset purchase or a deemed asset purchase under Section 338 of the Internal Revenue Code is not available. A Section 336(e) election combines substantially similar tax consequences as a Section 338(h)(10) election (i.e., a step-up in the tax basis of the target corporation’s assets) with a simpler transaction structure. Read more
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News and Events
Recent Press Releases
April 13, 2015
March 31, 2015
In March Dentons’ Russian Tax practice held a seminar on intragroup transactions at its Moscow office. The seminar was held over the course of two days because of the considerable interest in it. The seminar attracted over 130 representatives of major Russian and foreign companies. Read more
March 4, 2015
Dentons today announces the promotion of nine lawyers to Partner and 14 to counsel across its offices in Europe. The promotions are effective from 1 January, 2015. The number of female partners account for 67% of the promotions this year which included a range of practice areas across Poland, France, Germany, Prague and Bratislava. Read more
Dentons Kyiv Tax Associate, Viktoria Fomenko, spoke at the International Fiscal Association Ukraine Seminar entitled “Application of ECHR Practice in the Ukrainian Tax Disputes.” The seminar was held on 25 February 2015 and discussed how the ECHR practice could be applied to the tax disputes in Ukraine and whether Ukrainian courts follow ECHR practice in their considerations. Read more
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