We can assist you with structuring acquisitions, dispositions and joint ventures involving foreign operations, including tax efficient financing, step-up planning and foreign tax reduction planning. Very often, tax reduction strategies can be employed in the acquisition context that would otherwise involve significant risks. These strategies can be implemented with minimal risk in the acquisition context due to the fact that the business changes necessitated by the acquisition provide the required business purpose for transactions that might otherwise be lacking. We can also assist you with international tax due diligence related to M&A transactions (e.g., reviewing risks related to subpart F income and FTCs).