Summer A. LePree
Partner
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Summer represents businesses and their owners in a variety of transactional tax matters, with a particular focus on international planning and transactions.
Key Matters
Some of the experience represented below may have been handled at a previous firm.
- Assisted with restructuring of global private equity fund, where majority interests are held by US citizens living in France, to maximize global tax efficiency in light of 2017 US tax reform law. Guided specific cross-border tax planning for sale of certain current holdings.
- Represented real estate development company with structuring substantial outbound investments into Barbadian real estate. Later represented the company with restructuring such investments in connection with split-up transactions, including disposition and loss planning, basis transfer issues, and overall outbound restructuring for future realization of GILTI after 2017 tax reform.
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Restructured entities to avoid currency restrictions in Belize, in order to facilitate partial sale of craft beer company to global brand and distributor and advised on US tax resulting from the restructuring and sale.
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Advised on a cross-border structure for an investment fund of Chinese investors making inbound investments into US life settlement policies. The structuring utilized provisions of a US income tax treaty to minimize the fund’s US tax burden.
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Assisted a large technology and software company specializing in software services to global 1000 companies with restructuring global operations to minimize worldwide tax on income from US and foreign-source software sales.
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Advised inbound lending fund on season and sell structuring to minimize risk of US trade or business classification, and general inbound tax planning to minimize US taxation of associated income, including impact of interest-stripping limitations under Section163(j) on deductibility of interest after 2017 tax reform and deduction of accrued but unpaid interest pursuant to Section 267(a)(3).