Taxation

Transactional Tax Structuring

We advise on the tax architecture behind cross-border deals, corporate reorganizations, and investment platforms. Our work includes:

• Structuring equity and debt instruments for tax efficiency across U.S. and Latin American jurisdictions
  
  
• Planning for step-ups, basis management, and exit alignment in M&A and private equity transactions
  
  
• Implementing holding company structures in treaty-aligned or tax-neutral jurisdictions
  
  

Cross-Border Tax Planning

We assist clients with dual tax obligations—U.S., Mexico, Colombia, and beyond.

• Leveraging treaty benefits and foreign tax credits to reduce double taxation
  
  
• Advising on Controlled Foreign Corporation (CFC), GILTI, Subpart F, and PFIC exposure
  
  
• Coordinating inbound/outbound planning for founders, investors, and international expansions
  
  

Regulatory Compliance & Disclosure

We support compliance with the world’s most demanding tax reporting regimes.

• FATCA, CRS, BOI, and local UBO disclosure strategy
  
  
• IRS and DIAN reporting for foreign entities, trusts, and passive assets
  
  
• Pre-immigration, expatriation, and voluntary disclosure planning for global taxpayers
  
  

Virtual Assets & Emerging Tax Classes

We advise on the tax implications of holding, transferring, and tokenizing digital assets.

• Structuring token issuances, SAFEs, and digital equity for tax clarity and regulatory defensibility
  
  
• Advising on character classification (property vs. income), sourcing, and cost basis tracking
  
  
• Navigating the intersection of virtual asset taxation and cross-border enforcement

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