Natan’s practice focuses on international tax planning, with
a particular emphasis on foreign tax credits, the subpart F regime, foreign
currency transactions, and other aspects of outbound tax planning. He has
extensive experience advising U.S. based multinationals on offshore
restructuring transactions, foreign tax credit and repatriation planning, intellectual
property transactions, and the use of partnerships in cross-border structures.
Natan also advises foreign companies on inbound tax matters, including
withholding tax questions, the application of tax treaties, and the taxation of
U.S. branches. He has represented clients in connection with IRS challenges
relating to foreign tax credits and other international tax issues. Natan is a
frequent speaker on international tax developments and transactions.