| What has Hamilton &
MacAvery done recently? Favorably interpreted an IRS
ruling and other authorities which generated significant
tax refunds for an internationally known service organization.
Recommended successful international and domestic
tax strategies which were implemented by a foreign
based industrial company to facilitate its acquisition
of a US based Fortune 500 company.
Successfully negotiated the settlement of a complicated
IRS audit for a cross-border airline leasing company
which included proposing a solution to resolve a question
concerning transfer pricing issues advantageous to
the client.
Completed several large consolidated tax returns involving
foreign and multi-state filings for industrial and
service organizations involving the application of
a number of tax planning strategies to achieve significant
federal and state tax savings.
Recommended a multi-national financing and leasing
structure in light of the recent anti-conduit tax
regulations.
Structured the re-negotiation of debt and changes
in the make-up of investors of a foreign based company
with US real estate operations through the use of
partnerships.
Advised a large international shipping company with
respect to restructuring to take advantage of the
treaty exemption from U.S. income tax.
Recommended strategies for rearranging offshore operations
for a casualty insurance company.
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