Aaron Payne represents publicly traded global corporations in the area of federal corporate taxation with respect to domestic and international planning, transactions and compliance. Aaron analyzes global issues and then structures deals accordingly in the context of acquisitions, dispositions and reorganizations. He advises clients regarding repatriation techniques, currency transactions, principal and finance company arrangements and financial instruments with cross-border facets. Aaron works with clients to manage the international taxation implications of their M&A endeavors by crafting deals to create transaction and legal entity structures that optimize the company's tax outcomes.
On the internal planning side, Aaron advises on repatriation structures to help clients efficiently meet their cash-flow needs as well as how to organize their international legal entities such that they are efficiently postured for U.S. tax purposes. In the area of corporate tax planning, Aaron advises multinational Fortune 100 clients in all aspects of their cross-border transactions. This activity includes subpart F planning, as well as tax compliance and tax information reporting.
Sutherland represents leading food and beverage company in spinoff of North American grocery business.
Sutherland serves as Kraft Foods' tax counsel in Cadbury acquisition.
Sutherland represents Philip Morris as tax counsel in purchase of Canada's Rothmans, Inc.