Andrea’s experience prior to joining Thompson Hine includes:

• Represented a global automotive parts company on U.S. tax consequences of corporate restructurings, including obtaining private letter rulings from the IRS Associate Chief Counsel, cross-border tax planning, debt refinancings, bond offerings, international tax issues arising post-tax reform, including the repatriation tax, GILTI, the PTEP ordering rules, and foreign tax credit rules, and assisted in resolving a significant tax audit at IRS Exam and IRS Appeals
• Representing a Hawaiian client in arbitration proceedings on tax issues arising out of a tax-free split-off of a family business
• Counseled a client on structuring a Singapore reverse takeover transaction to fall outside U.S. anti-inversion rules
• Advising a leading South American consulting company in the architecture, engineering and construction industry on the U.S. tax consequences of restructuring and expanding its business into the United States
• Represented a leading European retailer of gift experiences on U.S. tax aspects of expanding business into United States, including permanent establishment and other U.S. tax treaty issues arising under cross border business model for marketing and sales operations
• Represented, as part of a team, the official creditor committee of one of the world’s largest manufacturers of automotive parts on the tax aspects of its cross-border insolvency proceedings pursuant to an asbestos-related chapter 11 plan of reorganization
• Advised a multinational Norwegian risk management corporation on the internal restructuring of its domestic operations in various business sectors following merger with a leading organization in same field
• Advised a global beauty company on the U.S. tax consequences of restructuring its international operations pursuant to nontaxable reorganizations and intragroup stock transfers
• Advised a leading U.S.-based casual dining restaurant company on the U.S. tax consequences of restructuring its domestic operations under a new holding company structure
• Advised high net worth client families in structuring real estate acquisitions including tax considerations of U.S. trade or business and effectively connected income analysis, the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), passive foreign investment company (PFIC) considerations, the active rents and royalties exception to subpart F, withholding tax issues and information reporting requirements
• Advised foreign financial institutions on U.S. tax aspects of lending, portfolio investments and corporate financing structures