Tyler J. Hawkins' practice focuses on tax planning and cross-border advisory services for multinational and inbound companies. Tyler drafts tax opinions, memoranda, transaction decks and micro step plans, transaction reporting matrices and disclosures, gain recognition agreements, and tax impact models. He also reviews legal documents, corporate governance articles, debt instrument documentation, valuations, and diligence reports.
Representative Matters
- Advised a Japanese inbound company from feasibility through implementation on approximately $5 billion post-acquisition integration and decontrol project
- Advised a U.S. multinational company on approximately $500,000 cross-border integration restructuring involving multiple recapitalizations, triangular reorganizations, and 304 sales
- Advised a U.S. multinational company on internal restructuring to unwind its two-tier Luxembourg holding company structuring
- Advised a U.S. multinational company on an internal restructuring to capitalize its foreign operating companies and provide a sustained, go-forward reduction in U.S. tax cost on Global Intangible Low Taxed Income (GILTI)
Judicial Internship
Hon. Robert E. Colville, Superior Court of Pennsylvania, July 2010-August 2010