ESTUDIO LEVENE


Lawyers & Tax Advisors



Estudio Levene is a boutique professional firm that offers tax and legal advice tailored to clients of all sizes and stages of the business. We consider ourselves a boutique firm because our clients deal with senior professionals only.


We advise clients on their business and personal needs both at home and abroad. In this globalized, fast moving and increasingly regulated world the need for integrated and timely advice has never been more important for managing businesses and wealth.


We focus on maximizing value for our clients while remaining mindful of professional expenses. Our team obtained tax and legal education in EU and the US and were trained working for top local and international professional firms dealing with complex issues for multinationals, entrepreneurs and high wealth individuals.
- Corporate -

We frequently act as general counsel, advising on all legal aspects of their day-to-day operations and deal flow.

Like most firms we have a corporate department that provides broad legal advice on commercial issues, including IP and employment and labor law issues. What makes our team different is that we provide a unique combination of corporate experience integrated with local and international tax advice.

Clients include entrepreneurs, privately owned businesses operating across numerous business sectors such as brands, healthcare, manufacturing, retail, services, hospitality, information technology and media.

Key to our advice is gaining a detailed understanding of each client's business goals. Thanks to our close working relationship with clients, we understand the interrelated nature of legal and business and cross border consequences, and the effect that these factors can have on our clients' corporate legal needs.

We have a particular focus on cross-border investment strategy and with correspondents worldwide, including US and European qualified lawyers, accountants and other service providers, we are able to work with global clients in a seamless, integrated and efficient manner.
Experience tells us that an entrepreneur is always a busy person with too many complex issues to attend with never sufficient resources. Since we understand this we have a practical and cost-effective approach towards tax and legal needs of our entrepreneur community of clients.

Our team regularly advises entrepreneurs and their businesses and families by providing commercial and tax planning solutions at all stages of their endeavours across many international markets.

We advise entrepreneurs on:

• early stage mentoring
• start up legal and tax structures
• commercial arrangements
• corporate structuring
• management and governance
• raising capital
• joint ventures
• strategic alliances
• mergers and acquisitions
• networking within our community of clients and network of angels
• incentive plans for employees (stock option plans, phantom stock, etc.)
• IP protection in Latin America, US, Europe, China, etc.

Our experience representing angel and venture capital investors enables us to provide valuable guidance to companies involved in capital raising transactions, exit strategies, including best practices for managing relationships with boards of directors and investors. We have represented emerging companies from the start-up phase through final rounds of capital and M&A transactions. We advise on a daily basis to entrepreneurs dedicated to e-commerce, online advertising, software development, online gaming, online financial services, international trading of goods, fashion and design business, hospitality industry, among many others.
We regularly advise fund managers on all aspects of the formation, structuring and financing of regulated and unregulated funds in a cost effective way. We have experience in setting up different kind of pool in vehicles in the onshore or offshore world for different lines of business like private equity, film industry, real estate, hospitality industry, crypto currencies, green bonds, etc. Our expertise includes:

Design, establishment and management of pool in investment vehicles, including limited partnerships, companies, investment trusts and venture capital funds for investing in both established and emerging markets.

Experience in transactional private equity work, regularly advising on leveraged buyouts, take-privates, joint venture investments, consortium deals, secondary transactions and recapitalizations.

Due diligence projects relating to the underlying investments of private equity vehicles.

Fund management tax and legal planning.
The firm advises on mergers and acquisitions, joint ventures, partnerships, and strategic alliances.

We are engaged in private M&A and private equity transactions. Our clients include large and small companies and private equity firms and other participants in corporate transactions.

What differentiates our practice from that of other M&A law firms is that we are a tax driven firm, being local and international taxation a very important factor for this type of transactions.

Unlike a lot of firms that simply assign junior corporate lawyers to large due diligence exercises, we are able to deploy a cost-effective team of senior professionals well versed in the legal and tax aspects of an acquisition target’s businesses. We have the experience and know-how to assist the client in drafting and negotiating the most appropriate representations and covenants for each transaction agreement.

For large transactions that may exceed our size we will team with highly specialized and senior professionals being the priority the best result for our clients.
We are a tax driven firm. Our tax team provides innovative tax analysis solutions in all areas of taxation, both domestically and internationally. Tax planning is a dynamic area where advanced planning is fundamental when optimizing results and minimizing adverse consequences.

A key area on which we regularly advise clients is that of taxation of cross border transactions of goods and services (e.g., double taxation agreements, transfer pricing, exchange of information, etc.). We have extensive knowledge of this complex and every day changing area and are able to guide clients efficiently and thoroughly in order to minimize the incidences of the applicable tax rules.

In particular, we have experience with the relevant cross border tax issues arising in the most important jurisdictions like the US, Brazil, Mexico, Colombia, Peru, Chile, Argentina, Uruguay, Italy, Spain, UK, Ireland, Luxembourg, the Netherlands, etc.
We assist clients in the negotiation and closing of real estate acquisitions and sales, including the preparation of purchase agreements, financing documents, tax-deferred and multiple-party exchange agreements, escrow instructions and other related documents.

Our firm represents both landlords and tenants and has significant experience in leasing transactions, including retail leases, office leases, industrial leases and subleases.

Our team assists clients in all types of real estate development, including industrial, residential, hotel and downtown developments. We have experience in the creation and operation of residential, commercial and mixed-use condominiums and planned unit developments.

We represent clients seeking financing. Our team advises clients on current methods and alternatives in real estate financing and assists in the structuring and documentation of real estate mortgages, fiduciary structures, contracts of sale and other financing transactions, such as sale-and-leasebacks. Partnership, joint venture, and real estate investment.

We assist clients with real property issues and projects abroad, including acquisitions, leases, secured transactions and lending.

We deal with land use regulation and in project permitting before government entities. Together with special counsel our practice includes the preparation and processing of all local, state, and federal permit applications relating to land use and environmental regulation of development projects.
- Private Clients -

As one of the most experienced private client practices, we are fully integrated into complex, multi-faceted projects with clients on a global stage. We provide the following services:
A family office may be an entity set up to run a family's affairs which has separate legal personality from the family or just be a place where the family manages its affairs or it may be a network of employees and advisors in a number of different places who work together to run the family's investments.

We have real insight into the concerns of wealthy families. This insight helps us when we assist our clients to set up and operate their family offices.

We work on the establishment and governance of single and multi-family offices, and provide advice as they expand. Whether the family office is large or small, domestic or international, we provide the comprehensive and integrated legal and tax service required.

We usually work closely with other leading service providers in finance and investment, as well as accounting management.
We commonly advise on establishing and restructuring trusts, fiduciary structures and foundations both local and overseas. We have a wealth of experience in setting up private trust companies, purpose trusts, protectorship vehicles and foundations, all with an eye to applicable tax requirements and the areas of conflict between common law and civil law.

We have experience managing disputes whether for settlors/grantors, beneficiaries, trustees or protectors.

The long-term viability of commercial operations depends on a plan for orderly succession.

Our team advices individuals and families who own businesses. Our experience in estate planning and the inter-related areas of business and tax law gives us the know-how to offer a sound but practical advice. We work with clients to develop a succession plan to transfer management responsibility and financial assets, help protect the estate and business from legal disputes.
Our team helps successful families and entrepreneurs around the world structure their assets in a way that will preserve their wealth now and for future generations.

We advise on all aspects of wealth structuring, using domestic and international trusts and foundations, private trust companies in local as well as other jurisdictions and we co-ordinate the acquisition of appropriate investments.

Our advice covers the design and implementation of new structures, as well as reviewing existing structures. We also assist them in complying with the complex rules surrounding investments, accounting, taxes and compliance.

Some of our clients are local and others are international families with family members who have European or US connections and want to mitigate their exposure to tax.
We have acted for successful people and their families. We have built up an in-depth understanding of the personal tax needs of our high net worth clients, and we can help them mitigate their exposure to tax both during their own lives and for future generations.

Our tax team can bring valuable cross-border experience and knowledge to complex scenarios for clients with multi-jurisdictional interests.

Our role often involves structuring business affairs and family investments, investing in financial products, using trusts and other vehicles to structure investments, dealing with tax issues arising on divorce, and reducing inheritance and gift taxes .

Additionally, we help international clients to achieve significant tax benefits through our understanding of the cross-border regime regarding residence and domicile.

We have experience in dealing with US tax and compliance issues when there are US situs assets, US citizens, US green card holders, etc.

Our clients span a broad range of professional and entrepreneurial individuals, families, and landowners. We represent their interests in multiple jurisdictions.
Our specialized team of accountants with local and international expertise will help you with:

*Annual tax planning for high wealth individuals.
*Preparation and/or review of tax returns.
*Support tax audits carried out by national, provincial and municipal tax authorities.
*Load and control efficiency of the tax variable in the administrative processes at a personal or company’s level.
*Certifications and accounting reports: Revenue, Sales, Source of Funds (fixed assets and properties), Income and Expenditure for Tax Purposes.
Cesar Levene, “VAT on Services to the Company by its Directors”, Periódico Económico Tributario, N° 224, La Ley, Argentina, 2001.
Cesar Levene, “Tax on Financial Transactions”. Periódico Económico Tributario, Nº 226, La Ley, Argentina, 2001.
Cesar Levene, “Management Agreement. Tax Implications. Technical Assistance. Permanent Establishment ”, Revista Impuestos, 2001-B-2213, La Ley, Argentina, 2001.
Cesar Levene, “Cross Border Technical Assistance Service. Double Tax Treaties”, Periódico Económico Tributario, N° 240, La Ley, Argentina, 2001.
Cesar Levene, “Non-discrimination Principle in Double Tax Treaties”, Periódico Económico Tributario, N° 267, La Ley, Argentina, 2001.
Cesar Levene, “Stamp Duty. Technology Transfer Agreements”, Doctrina Tributaria, Tomo XXIV, 205, Errepar, Argentina, 2003.
Cesar Levene, “The Beneficial Ownership Concept in Double Tax Treaties”, in J. Casas (ed.) Substance Over Form Interpretation of the Tax Law, Editorial Abaco, Argentina, 2004.
Cesar Levene, “Common Law Trust. Recognition by civil law countries. Tax consequences”, Revista Argentina de Derecho Tributario, Year IV - 16 Oct-Dec, 2005, awarded diploma best published article 2006 by the Argentine Association of Fiscal Studies.
Carla Gruskin (co-authored), “Protocol on Government Procurement at the Mercosur”, Revista Argentina de Derecho Tributario, Año IV – 16, 2005. Premio mejor artículo de doctrina de la Asociación Argentina de Estudios Fiscales (IFA branch Argentina).
Carla Gruskin (co-authored), “Tax liabilities of directors and managers for tax debts of dissolved corporations”, Doctrina Tributaria, Tomo XXVII, 949, Errepar, Argentina, 2006.
Cesar Levene, chapter “Double Tax Treaties and Transfer Pricing”, in C. Goldemberg (ed.) Transfer Pricing in Argentina, La Ley, Argentina, 2007.
Cesar Levene, “Interest Expense Deduction in Leveraged By-Outs", IJ-XXIII-129, Argentina, 2007.
Axel Verstraeten, “The assignment of rights for the use on land on private cemeteries and the Value Added Tax”, Periódico Económico Tributario, No. 363, La Ley, Argentina, 2007.
Cesar Levene, “Tax ruling and Transfer Pricing”, Revista Derecho Fiscal, Lexis Nexis, Argentina, 2008.
Cesar Levene, chapter “Argentine report”, in The International Comparative Legal Guide to: Corporate Tax, Global Legal Group Ltd., UK, 2008.
Axel Verstraeten, “Argentina’s Struggle in Negotiating Double Tax Conventions”, Special Report, Tax Notes International, Vol. 49, N° 11, Tax Analysts, US, 2008.
Axel Verstraeten, “OECD Model: new version”, Periódico Económico Tributario, N° 404, La Ley, Argentina, 2008.
Axel Verstraeten, “Supreme Court confirms prior rulings on bad debt deduction”, Country Digest. Tax Notes International. Vol. 54, N° 1, Tax Analysts, US, 2009
Axel Verstraeten (co-authored), “Investing in Argentina: Loan or Equity”, Practitioners’ Corner, Tax Notes International, Vol. 53, N° 8, tax Analysts, US, 2009.
Axel Verstraeten, chapter “Double (Non-) Taxation in VAT and Direct Taxes: Which Tax Is Better for Developing Countries?”, in M. Lang, P. Melz and E. Kristoffersson (eds.) Value Added Tax and Direct Taxation, Similarities and Differences. International Bureau of Fiscal Documentation, Netherlands, 2009
Axel Verstraeten, “Deutsch case, is it an inflection point?”, Periódico Económico Tributario, N° 433, La Ley, Argentina, 2009.
Axel Verstraeten, “UBS case and the exchange of information”, Revista de Derecho Fiscal, N° 5, Lexis Nexis, Argentina, 2009.
Axel Verstraeten, “Austral case and the new decision on the concept of Argentine source”, Periódico Económico Tributario, N° 429, La Ley, Argentina, 2009.
Axel Verstraeten, “Income attribution in foreign controlled companies: A comparative analysis”, Periódico Económico Tributario, N° 423, La Ley, Argentina, 2009.
Axel Verstraeten, “Status of the commentaries to the model on double tax treaty for the avoidance of double taxation of the OECD”, Periódico Económico Tributario, N° 418, La Ley, Argentina, 2009.
Axel Verstraeten, “The Double Tax Treaty between Argentina and Chile”. Revista de Derecho Fiscal, N° 2, Abeledo Perrot, Argentina, 2009.
Axel Verstraeten (co-authored), “The Tax Treaty for the Avoidance of Double Taxation between Argentina and Bolivia”, in Villegas Aldazosa (ed.) Temas de Derecho Tributario en homenaje al Profesor Alfredo Benitez Rivas, Fundación Universidad Privada de Santa Cruz de la Sierra – UPSA, Bolivia, 2010.
Axel Verstraeten, chapter “Commentaries to the OECD Model Double Tax Treaty as a mean of interpretation”, in F. Garcia (ed.) Convenios para Evitar la Doble Imposición Internacional. Aspectos controvertidos, La Ley, Argentina, 2010.
Axel Verstraeten, “Union Pak case, the concept of source and permanent establishment in the income tax law”, Periódico Económico Tributario, N° 455, La Ley, Argentina, 2010.
Axel Verstraeten, “Exchange of information as a tax policy tool”, Periódico Económico Tributario, N° 438, La Ley, Argentina, 2010.
Axel Verstraeten (co-authored), “Argentina – chapter XX”, in The Inward and International Taxation Review, Law Business Research, UK, 2011.
Axel Verstraeten, “Regional Integration and tax harmonization”, Periódico Económico Tributario, N° 465, La Ley, Argentina, 2011.
Axel Verstraeten, “Searching the federal tax balance”, Periódico Económico Tributario, N° 460, La Ley, Argentina, 2011.
Axel Verstraeten, “The new version of the OECD Model Double Tax Treaty”, Anuario de Derecho Tributario, Universidad Diego Portales, N° 3, Chile, 2011
Axel Verstraeten, “Double Tax Conventions between developed and developing countries. The Argentina-United States´ case”, Diritto e Pratica Tributaria Internazionale, Vol. VIII, N° 1, Italy, 2011.
Axel Verstraeten, chapter “The Impact of the OECD and the UN Model Conventions on Argentina’s Bilateral Tax Treaties”, in M. Lang, J. Schuch, C. Staringer, P. Pistone and A. Storck (eds.) The Impact of the OECD and the UN Model Conventions on Bilateral Tax Treaties. Linde Publishers, Austria, 2012
Axel Verstraeten, “Personal Assets Tax: Courts´ news in Argentina”, Diritto e Pratica Tributaria Internazionale, Vol. IX, Nº 2, Italy, 2012.
Axel Verstraeten (co-authored), “Some concerns on the termination of the Double Tax Treaty between Argentina and Spain”, Special publication on the Double Tax Treaty between Argentina and Spain, Año 5, Nº 50, La Ley Online Checkpoint, Argentina, 2012.
Axel Verstraeten, “Argentina’s tensions with the permanent establishment concept”, Tax Notes International. Vol. 64, No. 3, Tax Analysts, US, 2012.
Axel Verstraeten (co-authored), “Consequences of the termination of the double tax treaty between Argentina and Chile”, Special publication on the Double Tax Treaty between Argentina and Chile, Year 5, N° 49, La Ley Online Checkpoint, Argentina, 2012.
Axel Verstraeten, chapters “Treaty abuse: Treaty shopping y treaty override" and (co-authored) "The Procedure on Mutual Agreement to solve international tax conflicts”, in R. Asorey and F. Garcia (eds.) Tratado de Derecho Internacional Tributario (Tomo I), La Ley, Argentina, 2013.
Axel Verstraeten (co-authored), chapter “Tax secrecy and tax transparency – the relevance of confidentiality in tax law – Argentina`s report “, in E. Kristoffersson, M. Lang, P. Pistone, J. Schuch, C. Staringer and A. Storck (eds.) Tax secrecy and tax transparency – the relevance of confidentiality in tax law. Peter Lang, Germany, 2013.
Axel Verstraeten (co-authored), “Molinos´ case: tax treaty abuse? (Part one and two) ”, Periódico Económico Tributario, N° 525 and 526, La Ley, Argentina, 2013.
Carla Gruskin, “Liability of the Trustee” and “Tax Issues of Trusts”, in G. Gotlib, F. Vaquero and M. Carregal (eds.), Tratado de Fideicomiso, La Ley, Argentina, 2013.
Carla Gruskin, “The cancellation of the Tax Identification Number. Does the purpose justify the means?”, La Ley - Tomo 2014 A, Argentina, 2014.
Axel Verstraeten, chapters “Fees and compensations received from and/or abroad” and “Presumptions applicable to the foreign source income obtained by local residents”, “”, in D. Fraga and R. Sericano (eds.) Presunciones y Ficciones en el Régimen Tributario Nacional (Tomo II), La Ley, Argentina, 2014.
Cesar Levene and Axel Verstraeten, “Recognition of common law trusts in Argentina and its tax consequences (Part 1 and 2) ”, The Journal of International Tax, Trust & Corporate Planning. Issues Nº 1 & 3, UK, 2014
Axel Verstraeten (co-authored), chapter “Exchange of Tax Information and the Impact of FATCA for Argentina”, in W. Byrnes & R. Munro (eds.) LexisNexis® Guide to FATCA Compliance, 3rd Edition, LexisNexis, US, 2015
Axel Verstraeten, chapters “Argentina: Petrobras Case: Is Argentine Minimun Presumed Income Tax covered in Tax Treaties” and “Argentina: Treaty entitlement and Abuse: Argentina´s Molinos Case”, in M. Lang et al (eds.) Tax Treaty Case Law Around the World 2015, IBFD & Linde, The Netherlands, 2016

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Address:
J.M. Gutierrez 3765, oficina 701 - (Palacio Bellini - Studio) C1425AHB, Buenos Aires, Argentina
Tel/Fax:
+ 54 11 4843 1561
Address:
Av. Bulevar Gral. Artigas 361 CP:11300, Montevideo, Uruguay
Tel/Fax:
+ 598 271 62602