|
|
|
|
Structure & Entities
Tax Efficiency
|
|
|
|
|
External Tax Counsel
Professional Relationships
Project Responsibility
Revenue Representation
Transactional Assistance
|
|
|
|
|
Cross Border Structures
Large Construction Projects
IP Maximization
Compliance
Sales Tax and VAT
|
|
|
APPROACH
|
|
Law
Practicality
Substance
Integration
Strategy
|
|
|
|
|
Richard Rubin
Graham Fryer
Peter Todd
|
|
|
|
Approach
Our approach is based on experience-proven fundamentals.
We are familiar with the relevant provisions of the US Tax Code, the UK tax laws, and South African tax law as they impact international transactions. We also ensure that we are suitably familiar with other jurisdiction tax laws as required to provide fully integrated tax advice. We are very aware of the fundamental difference between tax law and Revenue interpretation. Where feasible, positions are taken in line with Revenue practice and interpretation. In other cases we carefully assess the merits and consequences of alternative interpretations.
While it is true that law deals with matters of principle - and therefore is generally blind as to amount, we also believe that large amounts at stake merit extra consideration. This practical approach has resulted in significant success in matters involving large amounts, even where prospects of success did not initially appear favorable.
As important as form may be, success in a tax matter generally assumes and relies upon the existence of the necessary substance. We ensure the necessary substance exists to propagate the most appropriate taxpayer argument and defense.
While ensuring advice that works for domestic taxes – covering both inbound and outbound transactions, we also look to ensure the position works for foreign taxes.
We have come to recognize that being correct in law is not enough – it is also necessary to act in terms of a gameplan which looks to a broad strategy, including considerations of related consequences, timing and sequence. No gameplan invariably means an uncertain end result. Aside from substantive tax law, we also take account of procedural and other practical considerations where relevant. |
