Overview
Nick Ryan focuses his practice on US and international tax matters that arise during internal restructurings, securitizations, mergers and acquisitions, and other strategic transactions. In particular, he advises public and private clients on various tax aspects of cross-border and domestic transactions, including Section 988 transactions, cross-currency hedging, debt refinancing, foreign-derived intangible income deductions, Subpart F income, and foreign tax credits.
Results
- Advised a client on a multibillion-dollar cross-border intellectual property transaction*
- Advised a hospitality company on a cross-border financing structure and the implementation of a global franchise fee arrangement*
- Advised clients on the restructuring of their multibillion-dollar global financing structures*
- Advised clients on the US tax implications of various dollar and non-dollar denominated debt refinancings*
*Matter handled prior to joining McDermott.
