Sophisticated **International Tax Structuring**, **Cross-Border M&A**, and **Regulatory Consulting**. Leveraging deep insight to optimize global operations and preempt controversy.
Effective global tax planning requires more than just knowing the rules—it requires knowing how they were written.
Deepan Patel leverages high-level experience from Nelson Mullins (Of Counsel) and PwC's Washington National Tax practice to structure tax-efficient cross-border transactions for multinationals and high-net-worth investors.
This advisory capability is uniquely fortified by his tenure at the IRS Office of Chief Counsel, where he drafted key Treasury Regulations. We don't just defend against audits; we architect operations to withstand them.
Admissions
Education
Inbound/Outbound planning, entity classification, and repatriation strategies (GILTI/FDII).
Tax-efficient deal structuring, due diligence, and post-transaction integration.
Complex instrument analysis, hedging, and crypto-asset reporting under Chief Counsel guidance.
Strategic defense for audits, 3520 penalties, and U.S. Tax Court litigation.
Optimizing entity selection and jurisdiction for tax efficiency. We handle Subpart F, GILTI, and BEAT analysis for US-based multinationals and foreign investors entering the US market.
Consult on StructureAdvising on tax-free reorganizations, liquidations, and intercompany financing. We structure Real Estate Funds (REITs/FIRPTA) and IP migration strategies to minimize leakage.
Transaction AdvisoryWhen disputes arise, we pivot to defense. Managing IRS 3520 Penalty Abatement, FBAR Voluntary Disclosures, and Appeals negotiation with insider precision.
Secure DefenseCross-Border Mergers
Structured multi-jurisdictional acquisition
Regulatory Drafting
Co-authored Treas. Reg. § 451(b)
Inbound Real Estate
Fund structuring for foreign capital
L-1 Visa Planning
Pre-immigration asset protection
To discuss your legal needs, please contact our office.