Domestic and International Tax Law

At Hrenya Senatore LLP, our federal tax law practice covers a wide range of domestic and international matters. Our clients include U.S.-based companies with domestic and international tax issues, as well as non-U.S. based companies that require assistance with U.S. tax issues.

Tax Law Legal Services

For U.S. and non U.S.-based clients, our tax planning and transactional services span many situations in which tax law advice and assistance is required, such as:

  • Mergers and acquisitions
  • Joint ventures, partnerships, and collaborations
  • Reorganizations
  • Venture capital and other private equity fund matters
  • Public and private financing transactions (equity and debt)
  • Technology transfers
  • Transfer pricing
  • Controlled foreign corporations
  • Passive foreign investment companies
  • Application of income tax treaties
  • Related Internal Revenue Service tax controversy matters

Our clients include companies in diverse industries and markets, including:

  • Software
  • E-commerce
  • Semi-conductors
  • Biotechnology
  • Pharmaceuticals
  • Alternative energy
  • Venture capital and other private equity funds
  • Foreign investors in U.S. real estate
  • Service providers and manufacturers

We take pride in providing tax counsel with the highest level of professionalism, as well as dedication to each client’s specific needs. Many of our clients are referred by current and former clients. We also collaborate with small and mid-size law firms to provide high level tax services on mergers and acquisitions and other transactions.

Tax Law Matters Involving Employment Issues

At Hrenya Senatore, our unique combination of experience in both tax law and employment law enables us to address matters that raise unique questions in both areas, such as assistance with negotiating employment contracts for new or internationally-transferred executives and related tax planning, as well as employee secondments and transfers and related compensation and benefit matters.

Representative Matters

The following recently-completed or ongoing matters illustrate the range of our tax law services:

  • Acquisition of an emerging U.S. software company by a Canadian public company;
  • Tax planning related to the organization of a new U.K. pharmaceutical company and its Swiss branch by venture capital funds in Canada and the United States and related financing transactions;
  • Inversion of a U.S.-based pharmaceuticals company (into the U.K.), its related equity financing transaction, and the implementation of a research and development cost-sharing arrangement;
  • Tax planning related to the establishment of manufacturing operations in the Philippines by a U.S. based semiconductor company;
  • Venture capital debt financing transaction for a U.S. pharmaceuticals company;
  • Tax planning for an international venture capital fund and its principals in response to the Tax Cut and Jobs Act of 2017;
  • Negotiation of tax provisions in a license and collaboration agreement between an emerging U.K. pharmaceuticals company and a U.S.-based big pharma;
  • Tax planning related to avoiding passive foreign investment company status for an Irish pharmaceutical company;
  • Tax planning related to the reorganization of a U.S.-based software company to facilitate a financing transaction;
  • Tax planning and implementation of an equity compensation plan for a U.S.-based software company;
  • International tax planning for an emerging U.S.-based e-commerce company.

Domestic and International Tax Law Inquiries

U.S. companies and non-U.S. businesses wishing to discuss tax law concerns may schedule a consultation by calling our Denver office at 720.586.6388 or completing our online contact form.

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