Jeffrey Rubinger
Partner
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Jeff is known worldwide as the lawyer to seek out when companies require a creative, sophisticated solution to a complex international tax situation.
Key Matters
Some of the experience represented below may have been handled at a previous firm.
- Advised on internal tax restructuring for multibillion-dollar energy trading hedge fund. Our work enabled certain United States investors to obtain long-term capital gain on a portion of the funds earnings relating to energy futures contracts.
- Advised a US$5B hedge fund on synthetic investment, through total return swap, in publicly-traded REIT to avoid withholding tax on distributions to fund’s foreign feeder. Restructured entities to avoid currency restrictions in Belize to facilitate partial sale of a beer company to a global brand and distributor. Advised on minimizing U.S. tax resulting from the restructuring and sale. Additional restructuring ensured the availability of foreign tax credits, which was otherwise uncertain based on certain Belize tax issues.
- Advised on international tax planning for energy trading hedge fund in connection with investment by its Cayman feeder fund in a publicly-traded REIT via a total return equity swap.
- Provided tax advice in the structuring of an umbrella partnership real estate investment trust (UPREIT).
- Representation of real estate fund client in the private placement securities offering of a flagship private equity fund comprised of two separate real estate funds, one focused on debt investments and the other focused on direct residential and commercial investments. The funds' structures include more than 30 entities, including Cayman Islands and Netherlands entities and a REIT.
- Assisted client in structuring a publicly-traded timber REIT to allow for tax-free distributions and sale of shares to foreign investors.
- Assisted with the restructuring of a family-owned and family-run global private equity fund, where two-thirds of the family lives in France (some are U.S. citizens), and one third resides in the US, to maximize global tax efficiency in light of U.S. tax reform law. Guided specific cross-border tax planning for the sale of one of their current holdings.
- Restructured entities to avoid currency restrictions in Belize to facilitate partial sale of a domestic beer company to a global brand and distributor. Advised on minimizing U.S. tax resulting from the restructuring and sale to defer U.S. recognition of the gain from the sale. Additional restructuring ensured the availability of foreign tax credits, which was unclear given the unusual nature of the Belize tax system and the recency and lack of guidance on the global intangible high-taxed income (GILTI) provisions under U.S. law.
- Representation of a multimillion-dollar Malaysian investment firm regarding the restructuring of United States real estate investments. The restructuring allowed to achieve the most efficient tax structure prior to entering into a joint venture with the largest Malaysian sovereign our client wealth funds to invest in United States real estate.