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 C$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.
Pensions, Benefits and Executive CompensationApril 4, 2014
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 moreTaxAugust 16, 2013
The awards acknowledge the excellence of our tax group both collectively and individually. Read moreUnited StatesJune 14, 2013
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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Pensions, Benefits and Executive CompensationApril 14, 2014
On April 4, 2013, the US Internal Revenue Service (IRS) issued Notice 2014-19 ("Notice") addressing how retirement plans, qualified under Section 401(a) of the Internal Revenue Code of 1986, as amended ("Code"), must treat the marriages of same-sex couples in light of the Supreme Court's decision in United States v. Windsor, 133 S.Ct. 2675 (2013) and giving guidance about what affected plans must say and by when. Read moreTaxApril 11, 2014
In its verdict in Case C-190/12 (Emerging Markets Series of DFA Investment Trust Company), the European Court of Justice (ECJ) confirmed that investment funds based outside the EU should benefit from the EU's free movement of capital rule regarding investments in Europe. Thus, if an investment fund based in an EU member state can benefit from local income tax exemptions, then non-EU funds (for example, American or Canadian ones) investing in Europe should also be entitled to apply for such exemptions. Read moreParisApril 9, 2014
This client alert relates to the revision of the OHADA Uniform Act Relating to Commercial Companies and Economic Interest Grou Read more
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News and Events
Tax Credits and Tax-Advantaged InvestingChicago, ILJune 25, 2014
Join us at III Forks restaurant to enjoy complimentary cocktails, delicious food and exquisite views of the surrounding skyline. Read more
Recent Press Releases
Dentons’ Russian tax practice, representing major retailers AUCHAN, ATAK, Dixy, Stockmann, and Hyperglobus, achieved one of the most notable victories since the introduction of the RF Tax Code in a dispute concerning accounting for loss of stock. Read moreGermanyApril 8, 2014
The global law firm Dentons convinced the Supreme Tax Court in a revision proceeding that the so called minimum profit taxation is an infringement of art. 3 of the national constitution and is thus unconstitutional. Read moreParisMarch 24, 2014
The Dentons Paris office announces the promotion of four lawyers to Of Counsel. Read more
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