Photo of Robert D. Simon

Robert D. Simon assists clients in the tax ramifications of cross-border transactions. He frequently advises clients involved in mergers, acquisitions, restructurings, and dispositions of public and private companies. Bob has been involved in planning a number of major domestic and international reorganizations and spin-offs.

Bob has broad experience in tax planning for U.S. corporations operating abroad, including internal structuring for optimal tax results. His international tax practice is focused on all areas of "outbound" investment - emphasizing foreign tax credit planning, tax deferral, holding companies, the tax-efficient use of debt, the repatriation of foreign earnings, tax treaties and management of a company's worldwide effective tax rate.

Bob also advises foreign corporations who are purchasing U.S. businesses or expanding their existing U.S. operations. He has advised on all aspects of "inbound" investment, including capitalization of U.S. operations, restructuring, withholding tax, the repatriation of earnings, tax treaties and foreign investment in U.S. real property. Bob assists many foreign natural resource companies on their U.S. operations and acquisitions. Bob also advises real estate funds and investors, particularly with respect to the U.S. income tax consequences of investments by foreign investors, including sovereign wealth funds and pension funds.

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of

Continue Reading IRS and Treasury Department Finalize Qualified Foreign Pension Funds Regulations

This GT Alert provides a high-level summary of key tax provisions of the Inflation Reduction Act, which President Biden signed into law on Aug. 16, 2022.

Continue reading the
Continue Reading The Inflation Reduction Act – Key Tax Considerations

On Dec. 20, 2017, the House and Senate passed the Tax Cuts and Jobs Act, H.R.1, and this bill is on its way to President Trump for signature.  When signed into
Continue Reading GT Alert – Highlights of the Tax Cuts and Jobs Act