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Taxation of Corporate and Financial Transactions and Institutions

Taxation of Corporate and Financial Transactions and Institutions

Taxation of Corporate and Financial Transactions and Institutions

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Overview

Businesses pursuing transformational corporate or financial transactions face increasingly complex tax considerations. These can create significant risk, from structuring inefficiencies to regulatory challenges, that impact both the success of the deal and the long-term value created.

Regulatory scrutiny and evolving tax regimes, including FATCA, anti-hybrid rules and bank levies, mean that corporates and financial institutions alike must address tax issues in every stage of their transactions, from structuring through implementation. Clients therefore need advice that is technically excellent, commercially astute and aligned with their strategic objectives.

Corporate Transactions

Corporate clients trust us to advise them on all aspects of their strategic transformational transactions. We also act for providers of warranty and indemnity and other tax risk insurance in relation to risk assessment and policy cover/drafting, which in turn provides us with sector insight to assist corporate clients in relation to their insurance requirements. 

Our services include structuring and tax planning advice, using our deep knowledge to provide creative solutions, as well as taking care of the documentary side of implementation, including tax-related opinions and disclosure materials.   

Financial Transactions & Institutions

We act for banks and other financial institutions, financial intermediaries, borrowers and counterparties, advising on a wide range of tax issues on transactions, from domestic bank lending to complex cross-border structured financings. This includes real estate and infrastructure finance, projects, asset finance, debt capital market transactions, securitizations and derivatives, covering: 

  • Tax-deductibility of payments  
  • Tax treatment of income for banks and their branches 
  • Withholding taxes (including FATCA)   
  • Use of onshore and offshore securitization vehicles, and the availability of Applicable special tax regimes 
  • Tax treaty interpretation  
  • Application of “anti-hybrid” rules  
  • Bank levy   
  • VAT  
  • Transfer taxes and other indirect taxes  

Building intelligent tax solutions

Our expertise ensures that financial transactions are structured efficiently, while minimizing tax risks and enhancing regulatory compliance. With a global team, we provide integrated, cross-border support, delivering thoughtful, collaborative advice aligned with our clients’ strategic objectives. By combining technical excellence with deep commercial knowledge, we help clients navigate complex challenges with confidence.

A globally recognized team

Renowned for delivering exceptional results in an increasingly complex tax landscape, our team has consistently received excellent client feedback. These insights have been independently researched by tax specialist industry publications such as the International Tax Review, and leading legal directories Chambers and Partners and Legal 500.

“BCLP’s tax team is both technically excellent and commercially intelligent. They understand the context and commercial realities which drive transactions and are able to apply their advice in a way that fits that context.” - Legal 500 UK 2025, Corporate Tax


Alan I. Appel

Alan I. Appel
+1 212 541 2292

Alan I. Appel

Alan I. Appel
+1 212 541 2292
Frank A. Crisafi, Senior Counsel, Atlanta
Frank A. Crisafi, Senior Counsel, Atlanta
+1 404 572 6840

Meet The Team


Alan I. Appel

Alan I. Appel
+1 212 541 2292
Frank A. Crisafi, Senior Counsel, Atlanta
Frank A. Crisafi, Senior Counsel, Atlanta
+1 404 572 6840

Experience

Much of our work is by its nature confidential. Some recent examples include:

  • Acting for a European banking group’s investment management arm in structuring vehicles for lending into the UK including liaison with HMRC to ensure certainty of tax treatment.  
  • Acting for a major UK bank in relation to the application of the HMRC’s Code of Practice for Banks to certain transactions undertaken. 
  • Acting for a number of banks in relation to risk assessment and measures to govern risk in connection with the corporate criminal offence of failure to prevent the facilitation of tax evasion introduced by the Criminal Finance Act 2017.

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