Provided domestic and international tax advice to a Fortune 500 media and entertainment company on cross-border transactions and post-transaction business integrations. Transactions included cash repatriations, the spin-off of a large publishing business, a third-party joint venture with a private equity fund, intellectual property realignment of sports and film distribution rights, asset acquisitions, and internal restructurings. Worked directly with partners, the client, and advisors to third parties to advise on tax issues related to Subpart F, hybrid instruments, gain recognition agreements, tax treaties, conduit regulations and limitation on benefits provisions, FIRPTA, Subchapter C, and Subchapter K. Researched and drafted memoranda on partnership formations and terminations, outbound transfers, corporate reorganizations, FIRPTA, dual consolidated losses, and inversions. Drafted portions of a Private Letter Ruling for a large media and entertainment spin-off. Developed tax models to provide quantitative support for various planning alternatives. Collaborated weekly with foreign tax advisors to optimize U.S. and foreign tax efficiencies.