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Natan J. Leyva
Natan J. Leyva
Partner — Tax
Partner — Tax

Natan J. Leyva

Natan J. Leyva
Dallas

Trammell Crow Center
2001 Ross Avenue
Suite 3900
Dallas, Texas 75201

start quote symbolI enjoy the challenge of navigating complex and ever-changing international tax laws to come up with new and creative ways to tax-efficiently achieve a client’s business goals.end quote symbol
Natan J. Leyva

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 blank check company sponsored by an affiliate of Riverstone Holdings, in its business combination with Hammerhead Resources, a Canadian oil and gas producer

  • 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)
  • “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)