Ansgar Simon has a broad-based transactional tax practice. He regularly advises on mergers and acquisitions, restructuring transactions, recapitalizations, divestitures (including spin-offs), and the structuring of joint ventures, involving both corporations and partnerships for tax purposes. His advice also covers the financing of corporate and partnership transactions, the tax-efficient structuring for private equity funds and other alternative investment vehicles, and the tax-efficient structuring of inbound and outbound investments by and through such vehicles.
Mr. Simon has extensive experience advising clients on international tax matters. He regularly represents clients, including individuals, on inbound and outbound US federal income tax matters such as CFC and PFIC planning, related tax-efficient (re-)structurings, the repatriation of foreign earnings, foreign tax credit matters, the dual consolidated loss rules, foreign currency-related matters, the application and use of U.S. tax treaties, the existence of a U.S. trade or business or permanent establishment, the branch profits tax, FIRPTA, and the application of section 892.