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Natan J. Leyva
Natan J. Leyva
Partner — Tax
Partner — Tax

Natan J. Leyva

Natan J. Leyva
Washington

2200 Pennsylvania Avenue NW
Suite 500 West
Washington, DC 20037

start quote symbolI enjoy the challenge of navigating complex and ever-changing international tax laws to come up with new and creative ways to tax-efficiently achieve a client’s business goals.end quote symbol
Natan J. Leyva

Experience Highlights

  • Spartan Acquisition Corp. III, a SPAC, in its $3.14 billion business combination with Allego Holding B.V., a leading pan-European electric vehicle charging network

  • Decarbonization Plus Acquisition Corporation II, a SPAC sponsored by an affiliate of Riverstone Holdings, in its $1.2 billion business combination with Tritium, a Brisbane-based developer and manufacturer of direct current fast chargers for electric vehicles

  • TC Energy in a $1.68 billion unit-for-unit simplification transaction between TC Energy and TC PipeLines, LP

  • The Lion Electric Company, a leading designer, manufacturer and distributor of all-electric medium and heavy-duty urban vehicles, in its $1.9 billion combination with Northern Genesis Acquisition Corp., a SPAC

  • First Reserve in its $135 million acquisition of TriMas Corporation’s Lamons business, a provider of industrial sealing and fastener solutions

  • Frank’s International in its merger with Expro Group

  • Hi-Crush Partners LP in its conversion from a master limited partnership to a C-corporation

  • CryoLife, Inc., a leading medical device and tissue processing company, in connection with its $225 million acquisition of JOTEC AG, a German-based developer of medical devices for aortic and peripheral vascular disease

  • Huntsman Corporation in its $522 million initial public offering of Venator Materials plc, a global chemical company incorporated in the UK

  • U.S. based multinationals in structuring offshore operations to achieve foreign tax credit and subpart F efficiencies

  • Non-U.S. based companies in structuring U.S. operations and investments to achieve favorable treaty treatment

  • Global technology and manufacturing companies in developing their intellectual property exploitation structure and strategy

  • Multinational companies in integrating acquisitions using both corporate and partnership structures

  • Financial industry companies in designing their cross-border funding structures

  • Multinational companies in analyzing U.S. tax consequences of cross-border reorganizations and restructurings 

Credentials

  • Yale University, J.D., 1999
  • Harvard University, A.B., summa cum laude, 1996
  • Adjunct Professor, LL.M. in Taxation Program, Georgetown University Law Center (2012-2016)
  • Legal 500 U.S., Tax: International Tax, 2017, 2019, 2021, 2022
  • The Best Lawyers in America© (BL Rankings, LLC), Tax Law, 2020 and 2021
  • Member: D.C. Bar Association
  • Member: American Bar Association’s Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers (FAUST)
  • District of Columbia
  • New York
  • “Foreign Tax Credit Regulations – What’s New, Different, and Implications,” ABA Midyear Tax Meeting, February 2, 2022 (moderator)
  • “Cross-Border Transactions affected by Possible Changes to Tax Law,” ABA Midyear Tax Meeting, February 2, 2022 (moderator)
  • “Partnership Taxation: International Partnership Issues,” D.C. Bar Association’s Tax Legislative and Regulatory Update, January 12, 2022 (panelist)
  • “Branch Loss Recapture Under the Tax Cuts and Jobs Act,” Tax Executives Institute – Houston Chapter monthly meeting, April 22, 2021 (speaker)
  • “Tax and Accounting Year-End Update,” V&E Austin Office, December 5, 2019 (presenter)
  • “International Tax Reform: What You Should Know About GILTI and BEAT,” Annual In-House Symposium 2018, April 27, 2018 (speaker)
  • “Partnerships, U.S. Tax Reform and International Tax Planning,” 2018 International Fiscal Association Annual Conference, February 22, 2018 (speaker)
  • “What Technology Clients Need to Know About the New Tax Act,” Intellectual Property CLE Series, V&E Houston Office, February 1, 2018 (speaker)
  • “Implications of the Tax Cuts and Jobs Act for International Businesses,” Tax Reform Webcast, December 19, 2017 (speaker)
  • “International Provisions of the Tax Reform Bill for Multinationals,” Tax Reform Webcast & Teleconference, November 6, 2017 (speaker)
  • “District Court Invalidates Section 7874 Inversion Regulation and Opens Door for Challenges of Certain Temporary Regulations,” V&E Tax Update E-communication, October 9, 2017 (co-author)
  • “A Greek Company Mines for Magnesite and Strikes Gold for Inbound Investors,” V&E Tax Update E-communication, July 17, 2017 (co-author)
  • “Foreign Activities of US Taxpayers, Foreign Lawyers Forum, Transfer Pricing, and US Activities of Foreigners and Tax Treaties,” ABA Tax Section 2017 Midyear Meeting, Orlando, Florida, January 20, 2017 (panelist)
  • “Subpart F Income Tax: Its Scope and Application to US Shareholders,” ABA Tax Section 2017 Midyear Meeting, Orlando, Florida, January 19, 2017 (panelist)
  • Comments Regarding the Proposed Regulations on Related-Party Debt Instruments (Section 385), District of Columbia Bar Taxation Section, June 2016 (co-drafter)
  • “Use of Partnerships in International Tax Planning,” International Fiscal Association Annual Conference, Miami, Florida, February 25, 2016 (moderator)
  • “Taxing Foreign Goodwill & Going Concern Value Under Section 367,” ABA Section of Taxation 2016 Midyear Meeting, Los Angeles, California, January 29, 2016 (panelist)
  • “Inversions Under Section 7874: A Primer,” Practising Law Institute, The Corporate Tax Practice Series: Strategies for Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings, Volume 20, July 2014 (co-author)