Eduardo Cukier's transactions-based domestic and international tax practice spans more than two decades advising U.S. and foreign clients across many different types of business deals in various industries. He counsels companies, governments, investment funds, family offices, and high-net-worth individuals in a wide range of transactions, such as mergers and acquisitions, restructurings, joint ventures, and financings.
With exceptionally broad experience and deep insight, Eduardo enables his clients to achieve maximum deal value by limiting and managing potential tax liabilities and risks. His clients include U.S. and foreign multinational public and private corporations, partnerships, private equity firms, investment management firms, governments and governmental entities, as well as entrepreneurs, family offices and high-net-worth individuals. His clients come from a wide variety of industries, including consumer goods, commodities, manufacturing, transportation, real estate, banking and financial services, energy and technology.
Clients rely on Eduardo for strategic tax and business planning in the context of domestic and cross-border mergers, entity and asset acquisitions, spinoffs and divestitures, business startups, restructurings, joint ventures, equity and debt financings, and securities and capital markets transactions.
He advises U.S.-based clients on structuring domestic and foreign investments and operations, addressing outbound considerations of asset transfers, leveraging foreign tax credits, and planning under the GILTI, Subpart F, and PFIC anti-deferral regimes. He also represents U.S. and foreign clients in tax audits and litigation involving federal, state and local tax authorities, and provides them with overall guidance in their corporate operations and transactions based on their business goals, the economics involved, inherent risks, and potential benefits.
Eduardo brings an international perspective, cultural awareness, and an understanding of legal and tax systems, regulatory frameworks, and the business dynamics involved in getting deals done. That skill set has made him counsel of choice for many corporations, businesses and entrepreneurs in the U.S., Latin America, and around the globe. Multinational businesses and foreign-based high-net-worth individuals and families, look to Eduardo to structure 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. He works closely with a top-level network of foreign tax counsel to ensure optimal global tax efficiencies for his clients.
Fluent in both English and Spanish, Eduardo communicates well with clients ensuring they readily understand the tax implications of their transactions.
He is a sought-after speaker on U.S. and international tax topics.
Columbia Law School, J.D.
