Emin Toro’s practice concentrates on the needs of multinational companies, including both tax controversies and counseling. Mr. Toro’s controversy experience includes audits, administrative appeals, litigation, as well as advance pricing agreement and competent authority proceedings. Mr. Toro has handled controversies in a number of subject matter areas, including cross-border trading structures, cost sharing arrangements, income and expense reallocations under Section 482, royalty arrangements, contract manufacturing and distribution arrangements, foreign tax credits, treatment of corporate reorganizations and restructurings, computation of allowable FSC benefits, and allowance of losses on subsidiary stock and debt.
Mr. Toro has provided counseling on tax-efficient cross-border distribution structures, cross-border services, cross-border transfer pricing, international asset transfers, and tax optimal corporate structures, as well as acquisitions and dispositions.