Gerente Jurídico (Assistant General Counsel)
São Paulo Area, Brazil
• Served on special committees of the Ministry of Finance that advised on a new regulatory framework for controlled foreign corporations (CFC) and transfer pricing rules for commodities. • Counseled on income tax, transfer pricing, CFC rules, tax planning and tax litigation. • Managed the corporate matters of thirty-three offshore companies in seven countries (e.g., merger, spin-off, split-up, split-off, dissolutions and reorganizations towards tax efficiency). • Participated in the unsolicited takeover bid for a major Portuguese company (e.g. incorporated offshore SPVs, drafted prospectus and advised officers on the US$6 billion offering of commercial papers). • Structured local and cross-border M&A transactions and joint ventures. • Drafted and negotiated international trade agreements (e.g. iron ore export). • Represented company in a AAA international arbitration in NY.