Eduardo Cukier

WORK HISTORY

EDUCATION

SKILLS

ABOUT EDUARDO CUKIER

I provide sophisticated tax planning advice to U.S. and foreign clients on domestic and cross-border mergers and acquisitions, restructurings, spinoffs, joint ventures, asset acquisitions and divestitures, equity and debt financings, and securities and capital markets transactions.I advise U.S-based clients on structuring domestic and foreign investments and operations, including outbound considerations of asset transfers, foreign tax credits, and the GILTI, Subpart F, and PFIC anti-deferral regimes. I advise non-U.S-based clients on structuring inbound U.S. investments and operations to maximize benefits under U.S. income tax treaties and minimize tax and risks under U.S. permanent establishment, Foreign Investment in Real Property Tax Act (FIRPTA), and earnings-stripping rules. I work extensively with foreign tax counsel to maximize global tax efficiencies for clients. I represent U.S. and foreign clients in tax audits and litigation involving federal, state and local tax authorities.I represent a diverse group of clients, including U.S. and foreign multinational public and private corporations, partnerships, private equity firms, investment management firms, governments and governmental entities, family offices and high-net-worth individuals, across a broad range of industries such as consumer goods, commodities, energy, technology, manufacturing, transportation, real estate, banking and financial services.I frequently chair panels and present at tax conferences on U.S. and international taxation. I am fluent in Spanish.