Michael Hardgrove has provided international tax consulting, legal entity structuring and intangible property transaction services to numerous public and private companies with operations throughout the world.

Michael’s practice focuses on optimizing the potential benefits of international structures and business operations, including assessing international tax exposures, recommending efficient strategies, and executing the legal steps required to meet the primary objectives of minimizing costs, lowering tax rates and improving cash flows. 

His team of lawyers, economists and tax professionals consistently deliver on achieving international tax and structuring objectives.  Whether driven by events such as equity transactions, business growth, new technology or product development.  

This proactive and unique legal practice has often been recognized for its consistent capabilities in identifying opportunities, advocating defensible positions and advising on strategic approaches to manage international tax matters:

  • International Structuring:  developed efficient global legal entity structures that created efficiencies, limited financial exposures, positioned intangible property rights and designed intercompany arrangements
  • Global Alignment:  achieved M&A transaction value and synergies following deal closings by utilizing structural simplification, appropriate transfers of intangible property and streamlining of intercompany transactions
  • Regional Supply Chain:  created efficiencies with centralization of procurement, manufacturing oversight and distribution, resulting in increased controls, improved standardization and enhanced profitability. 
  • Controversy services:  privileged and confidential advice, file memoranda, legal opinions, advanced tax agreement negotiations, tax audit defence, financial audit positions and tax appeals procedures