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International Tax

The hallmark of Vinson & Elkins’ International Tax practice is the ability to handle the complexities of international taxation in a practical, commercial manner. We represent foreign and domestic clients across a broad range of industries, including energy, finance, technology, and real estate. Whether structuring new “inbound” or “outbound” investments or advising on the U.S. or UK tax aspects of cross-border transactions, we are equipped to handle the most sophisticated transactions. With V&E’s decades of experience handling matters around the globe, we are able to provide creative and practical solutions to emerging international tax issues.

V&E's services encompass a broad spectrum of international tax planning, including: 

  • Formations of new financing and ownership structures
  • Cross-border mergers and acquisitions and public offerings
  • Expansions into new markets
  • Cross-border commercial transactions
  • Transfer pricing planning and implementation
  • Strategic international tax planning and restructuring

Global Reach

V&E’s International Tax practice includes a dedicated team of lawyers based in our U.S. and London offices. In addition, we have built close working relationships with leading tax practitioners in local markets who share our philosophy of client service. Leveraging these relationships, we can help our clients assemble the right team for the project.

Additional Information

Practice Highlights

  • Talos Energy LLC, as member of a consortium and Operator, in its successful bid for two awarded offshore blocks in Mexico’s first hydrocarbons auction and other matters in respect of their operation and joint ownership
  • Devon Energy Corporation in the $7 billion sale of all of its Brazilian, deep Gulf of Mexico, and Azerbaijan assets to BP, as well as its purchase of a 50 percent interest in an oil sands project in Alberta, Canada
  • Buckeye Partners, L.P. in structuring its investment in a 50% stake in the VTTI Group, one of the largest independent global energy terminal businesses, with an implied total value of $2.3 billion 
  • Riverstone Holdings in the formation and $525 million line of equity commitment to Sierra Oil & Gas, Mexico’s first independent exploration and production company
  • Soros Fund Management in structuring an investment by Quantum Strategic Partners in Zenium Technology Partners, a data center development and management company with facilities located in developed and emerging markets
  • Transelec S.A. in connection with the development and project financing of a 188 km electric transmission line that delivers energy to the Caserones copper mine in Chile
  • AES Gener S.A. in connection with the development and $1.05 billion project financing of the Cochrane power plant in Chile, a 472 MW (net) pulverized coal-fired generating facility in Chile, with financing provided by JBIC, NEXI, K-Sure, and various commercial banks
  • Devon Energy in its $1.4 billion joint venture with Sumitomo, involving 650,000 shale acres in the Permian Basin (Cline Shale and Midland-Wolfcamp Shale), by Japan’s Sumitomo
  • Texas Pacific Group with respect to structuring a $300 million equity investment in M&G Chemicals, a company organized in Luxembourg with manufacturing facilities in Brazil, Mexico, and the United States
  • C&J Energy Services in its $2.86 billion merger with Nabors’ completion and production businesses to create a leading diversified completion and production services provider headquartered in Bermuda
  • An MLP with respect to the structuring of a joint venture to build a facility in China using the MLP’s proprietary intellectual property 
  • A publicly-held Brazilian independent oil company on the acquisition of a 60% operating interest in the Polvo field and on the sale of its interest in the Solimoes oil basin
  • A multibillion dollar natural gas company based outside the United States in the structuring of its worldwide trading operations
  • A multibillion dollar credit fund in structuring its lending and investment activity with respect to approximately $5 billion of cross-border debt securities
  • A U.S.-based start-up company and its Middle East-based parent in structuring their worldwide operations and intellectual property holdings
  • A foreign manufacturer, relating to U.S. trade or business issues arising from transactions with U.S.-based customers
  • A foreign energy company, relating to tax treaty issues arising from hedging transactions

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