Eduardo A. Cukier

Partner

Cukier, Eduardo

Eduardo Cukier is a tax partner in the New York office. For more than 20 years, he has been providing U.S. and foreign clients with sophisticated tax planning advice on a full range of domestic and international taxation issues relating to cross-border mergers and acquisitions, restructurings, spinoffs, asset acquisitions and divestitures, equity and debt financings, securities and capital markets transactions. In addition, Mr. Cukier has extensive experience advising U.S. and foreign partnerships, private equity funds, real estate and high net worth investors in a broad range of transactions involving international, federal, state and local taxation issues. Mr. Cukier has extensive experience advising clients on executive compensation, insolvency and bankruptcy restructurings, as well as representing clients in tax controversies and litigation involving federal, state and local tax authorities.

Global Tax Practice

Mr. Cukier’s practice is global in nature. He has advised U.S.-based clients on structuring foreign investments and operations efficiently in light of U.S. tax rules on controlled foreign corporations, Subpart F income, global intangible low-taxed income (GILTI), foreign tax credits, passive foreign investment companies and outbound transfers of assets. Mr. Cukier has advised foreign-based clients on structuring U.S. investments and operations efficiently in light of U.S. permanent establishment, the Foreign Investment In Real Property Tax Act (FIRPTA), withholding tax, check-the-box, interest deduction limitation and other earnings-stripping and anti-hybrid taxation rules. Mr. Cukier has extensive experience in structuring investments to maximize tax benefits under international tax treaties, and has worked extensively with tax counsel in foreign jurisdictions to maximize global tax efficiencies for his clients.

Diverse Clients and Industries in Tax Practice

Mr. Cukier has served as partner in charge of domestic and international tax matters for a diverse group of clients and industries. He represents a clientele that includes U.S. and foreign multinational public and private corporations, partnerships, private equity firms, family offices and high-net-worth individuals, as well as governmental entities. Mr. Cukier advises clients in industries as varied as commodities, energy, technology, manufacturing, transportation, banking and financial services, to name a few.

Professional Activities

Hofstra University School of Law, Special Professor of Law, International Taxation, 2007

Eduardo Cukier is a tax partner in the New York office. For more than 20 years, he has been providing U.S. and foreign clients with sophisticated tax planning advice on a full range of domestic and international taxation issues relating to cross-border mergers and acquisitions, restructurings, spinoffs, asset acquisitions and divestitures, equity and debt financings, securities and capital markets transactions. In addition, Mr. Cukier has extensive experience advising U.S. and foreign partnerships, private equity funds, real estate and high net worth investors in a broad range of transactions involving international, federal, state and local taxation issues. Mr. Cukier has extensive experience advising clients on executive compensation, insolvency and bankruptcy restructurings, as well as representing clients in tax controversies and litigation involving federal, state and local tax authorities.

Languages

English

Spanish

Recommended as a Leading Lawyer in 2016 and 2017

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