Tax

Our tax attorneys are proficient in helping businesses minimize their risk from a tax standpoint and maximize their business and financial goals. We have a broad depth of knowledge and expertise, allowing us to handle virtually all aspects of federal tax planning and even the most complex tax issues.

We are skillful in counseling clients as to the tax ramifications of all types of corporate transactions, including mergers and acquisitions, recapitalizations, spin-offs, reorganizations, equipment leasing, debt securitization, and joint ventures. We are adept at identifying the tax issues and assisting clients in identifying and formulating the tax strategies necessary to further their business objectives. Our tax attorneys also counsel clients on the tax implications of real estate transactions. Working in conjunction with our attorneys in our Real Estate Practice Group, we advise clients as to the proper vehicle for owning property and how to structure the real estate transaction to best minimize the tax consequences, including utilizing limited liability companies and grantor trusts.

We also provide aggressive, experienced representation before the Internal Revenue Service and state tax agencies for audits and collection matters. Taxpayers are entitled to many protections while under investigation in a tax controversy and the services of experienced tax counsel can reduce the potential for an adverse determination. When negotiation with the administrative arm of the IRS fails to secure a desired resolution, we have the experience to pursue judicial remedies to assure that our clients only pay the proper amount of tax.

Our clients in the tax area include Fortune 500 companies, mid-size businesses, family and closely-held companies, emerging start-up entities, and not-for-profit organizations, as well as individuals, trusts, and estates. In certain instances, we have been providing tax planning and other tax-related services to the same business for several decades.

Our services include:

  • Formulating efficient tax structures for mergers and acquisitions, taking into account each party’s business objectives and corporate and securities law issues
  • Advising clients in private equity and venture capital transactions in order to properly structure emerging businesses
  • Structuring real estate transactions, including like-kind exchanges, UPREITS, REMICS, and REITS
  • Structuring real estate acquisitions
  • Structuring and counseling with respect to taxable and tax-free mergers, reorganizations, acquisitions, divestitures, and spin-offs
  • Counseling regarding the tax and business aspects of partnerships, limited liability companies, joint ventures, business, and grantor trusts
  • Handling real estate tax issues
  • Providing tax planning for specific business transactions involving limited liability companies, C corporations, S corporations, and partnerships
  • Providing tax advice in connection with employee benefits
  • Preparing estate and gift tax returns
  • Assisting with organization and annual tax filings for not-for-profit organizations
  • Counseling clients to determine their sales tax liability and assisting in mitigating that exposure through the negotiation of voluntary disclosure agreements and participation in tax amnesty programs
  • Representing clients in state and federal tax controversies at both the audit and litigation levels:
  • U.S. Tax Court
  • U.S. District Courts
  • Audit representation
  • Collection representation
  • Criminal investigation division defense
  • Offers in compromise
  • State tax agencies

As our clients’ businesses have become increasingly global in scope, we have also assisted them with a broad range of international tax issues.