Natan J. Leyva
Natan is an international tax lawyer with over two decades of experience. He primarily advises multinational corporations on cross-border aspects of the U.S. tax regime. He helps clients plan business deals and structure global operations in tax-efficient ways, and assists with mergers, acquisitions, and other transactions implicating cross-border issues. Natan has become a leading resource on the significant tax law changes introduced in the Tax Cuts and Jobs Act of 2017, and counsels clients daily on how to structure their activities and organizations in light of the new rules.
Natan has extensive experience helping U.S.-based multinationals organize their outbound tax affairs, with a particular emphasis on foreign tax credits, the base erosion and anti-abuse tax (BEAT), the global intangible low-taxed income (GILTI) and subpart F regimes, and foreign currency transactions. He advises clients on offshore restructuring transactions, repatriation planning, intellectual property transactions, and the use of partnerships in cross-border structures. Additionally, Natan advises foreign-based multinational corporations on their inbound tax matters, including withholding tax questions, the application of tax treaties, and taxation of U.S. affiliates. As part of his practice, he represents clients in connection with IRS challenges to international tax issues.
Natan is a frequent speaker on international tax developments and global tax planning.
Experience Highlights
Baytex Energy Corp. (TSX:BTE) in its $2.5 billion acquisition of Ranger Oil Corporation, a pure play Eagle Ford company
Aligned Data Centers in connection with a structured minority investment by SDC Capital Partners as part of the financing for the acquisition of Odata, a data center provider in Latin America
Chord Energy in its $11 billion combination with Enerplus Corporation
Core Laboratories in its reorganization, including the redomestication of the parent company from the Netherlands to the United States
Funds managed by Apollo in the $2 billion sale by New Fortress Energy Inc. of 11 LNG infrastructure vessels to a newly formed venture owned approximately 80% by Apollo funds and 20% by NFE
Goldman Sachs Renewable Power in its separation from Goldman Sachs Asset Management to form MN8 Energy, an independent renewable energy company and second largest U.S. independent solar and storage energy producer by capacity
Decarbonization Plus Acquisition Corporation IV, a SPAC sponsored by an affiliate of Riverstone Holdings, in its $1.39 billion business combination with Hammerhead Resources Inc., a Calgary-based energy company
Apollo Global Management in connection with Apollo Funds and Vitol agreeing to provide a structured debt and equity financing to WattEV, an industry leader in heavy-duty freight electrification providing end-to-end solutions to customers through the development of electric charging infrastructure and provisioning of electric vehicle trucks
Spartan Acquisition Corp. III, a SPAC, in its $3.14 billion business combination with Allego Holding B.V., a leading pan-European electric vehicle charging network
Decarbonization Plus Acquisition Corporation II, a SPAC sponsored by an affiliate of Riverstone Holdings, in its $1.2 billion business combination with Tritium, a Brisbane-based developer and manufacturer of direct current fast chargers for electric vehicles
TC Energy in a $1.68 billion unit-for-unit simplification transaction between TC Energy and TC PipeLines, LP
The Lion Electric Company, a leading designer, manufacturer and distributor of all-electric medium and heavy-duty urban vehicles, in its $1.9 billion combination with Northern Genesis Acquisition Corp., a SPAC
First Reserve in its $135 million acquisition of TriMas Corporation’s Lamons business, a provider of industrial sealing and fastener solutions
Frank’s International in its merger with Expro Group
Hi-Crush Partners LP in its conversion from a master limited partnership to a C-corporation
U.S. based multinationals in structuring offshore operations to achieve foreign tax credit and subpart F efficiencies
Non-U.S. based companies in structuring U.S. operations and investments to achieve favorable treaty treatment
Global technology and manufacturing companies in developing their intellectual property exploitation structure and strategy
Multinational companies in integrating acquisitions using both corporate and partnership structures
Financial industry companies in designing their cross-border funding structures
Multinational companies in analyzing U.S. tax consequences of cross-border reorganizations and restructurings
Credentials
- Yale University, J.D., 1999
- Harvard University, A.B., summa cum laude, 1996
- Adjunct Professor, LL.M. in Taxation Program, Georgetown University Law Center (2012-2016)
- Legal 500 U.S., “Leading Lawyer” in Tax: International Tax, 2024; Tax: International Tax, 2017, 2019, 2021, 2022
- The Best Lawyers in America© (BL Rankings, LLC), Tax Law (Washington), 2020, 2021, 2024, and 2025
- Member: D.C. Bar Association
- Member: American Bar Association’s Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers (FAUST)
- District of Columbia
- New York
- Not admitted in Texas
- Spanish (fluent)
- InsightDecember 18, 2024
V&E Tax Update
- InsightNovember 14, 2024
V&E Tax Update
- InsightNovember 5, 2024
V&E Tax Update
- InsightOctober 23, 2024
V&E Tax Update
- InsightOctober 8, 2024
V&E Tax Update
- Deals & CasesOctober 3, 2024
- InsightSeptember 19, 2024
V&E Tax Update
- Deals & CasesAugust 19, 2024
- Deals & CasesAugust 13, 2024
- Deals & CasesAugust 7, 2024
- Deals & CasesJune 28, 2024
- Rankings & AwardsJune 12, 2024
- Deals & CasesApril 1, 2024
- Deals & CasesMarch 8, 2024
- Deals & CasesNovember 8, 2023
- Rankings & AwardsAugust 21, 2023
- Deals & CasesFebruary 28, 2023
- Deals & CasesFebruary 7, 2023
- Deals & CasesJanuary 3, 2023
- Deals & CasesDecember 13, 2022
- Deals & CasesSeptember 9, 2022
- InsightAugust 23, 2022
V&E Tax Update
- InsightAugust 22, 2022
V&E Tax Update
- Deals & CasesAugust 4, 2022
- Rankings & AwardsJune 16, 2022
- Deals & CasesMarch 1, 2022
- Deals & CasesAugust 12, 2021
- “The Foreign Tax Credit: Latest Guidance,” Tax Executives Institute Mid-Year Conference, March 18, 2024 (speaker)
- “Year-end Corporate Tax Roundup,” TEI/Thomson Reuters, December 19, 2023 (speaker)
- “Foreign Tax Credit Regulations – What’s New, Different, and Implications,” ABA Midyear Tax Meeting, February 2, 2022 (moderator)
- “Cross-Border Transactions affected by Possible Changes to Tax Law,” ABA Midyear Tax Meeting, February 2, 2022 (moderator)
- “Partnership Taxation: International Partnership Issues,” D.C. Bar Association’s Tax Legislative and Regulatory Update, January 12, 2022 (panelist)
- “Branch Loss Recapture Under the Tax Cuts and Jobs Act,” Tax Executives Institute – Houston Chapter monthly meeting, April 22, 2021 (speaker)
- “Tax and Accounting Year-End Update,” V&E Austin Office, December 5, 2019 (presenter)
- “International Tax Reform: What You Should Know About GILTI and BEAT,” Annual In-House Symposium 2018, April 27, 2018 (speaker)
- “Partnerships, U.S. Tax Reform and International Tax Planning,” 2018 International Fiscal Association Annual Conference, February 22, 2018 (speaker)
- “What Technology Clients Need to Know About the New Tax Act,” Intellectual Property CLE Series, V&E Houston Office, February 1, 2018 (speaker)
- “Implications of the Tax Cuts and Jobs Act for International Businesses,” Tax Reform Webcast, December 19, 2017 (speaker)
- “International Provisions of the Tax Reform Bill for Multinationals,” Tax Reform Webcast & Teleconference, November 6, 2017 (speaker)
- “District Court Invalidates Section 7874 Inversion Regulation and Opens Door for Challenges of Certain Temporary Regulations,” V&E Tax Update E-communication, October 9, 2017 (co-author)
- “A Greek Company Mines for Magnesite and Strikes Gold for Inbound Investors,” V&E Tax Update E-communication, July 17, 2017 (co-author)
- “Foreign Activities of US Taxpayers, Foreign Lawyers Forum, Transfer Pricing, and US Activities of Foreigners and Tax Treaties,” ABA Tax Section 2017 Midyear Meeting, Orlando, Florida, January 20, 2017 (panelist)
- “Subpart F Income Tax: Its Scope and Application to US Shareholders,” ABA Tax Section 2017 Midyear Meeting, Orlando, Florida, January 19, 2017 (panelist)
- Comments Regarding the Proposed Regulations on Related-Party Debt Instruments (Section 385), District of Columbia Bar Taxation Section, June 2016 (co-drafter)
- “Use of Partnerships in International Tax Planning,” International Fiscal Association Annual Conference, Miami, Florida, February 25, 2016 (moderator)
- “Taxing Foreign Goodwill & Going Concern Value Under Section 367,” ABA Section of Taxation 2016 Midyear Meeting, Los Angeles, California, January 29, 2016 (panelist)
- “Inversions Under Section 7874: A Primer,” Practising Law Institute, The Corporate Tax Practice Series: Strategies for Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings, Volume 20, July 2014 (co-author)