The Tax Group advises a broad array of public and private clients in matters relating to the tax aspects of domestic and international corporate and commercial transactions, as well as counseling clients on tax-exempt, tax controversy and individual tax matters.
Our transactional tax services are designed to create tax-efficient structures that satisfy our clients’ business and financial objectives. Our tax lawyers are experienced with and regularly provide advice to clients in tax matters relating to:
- Complex domestic, international and cross-border taxable and tax-free mergers, acquisitions, dispositions and reorganizations, financing techniques, entity formations, recapitalizations, restructurings, divestitures, and other corporate and commercial transactions.
- All types of investment fund formations and operations, including advising hedge funds and private equity funds with domestic, foreign and tax-exempt investors and fund sponsorship structuring.
- International and cross-border tax matters, including matters relating to Controlled Foreign Corporations (CFCs), Passive Foreign Investment Companies (PFICs) and tax treaties.
- Sale and leaseback transactions and sale and management-back transactions.
- Derivatives and straddle transactions.
- Real estate transactions, including acquisitions, financing and restructuring and real estate investment trust (REIT) structuring and operational issues.
- Like-kind exchanges.
- Consolidated return issues.
- Individual business and personal transactions.
As a result of our broad experience in these and other areas, our tax lawyers have a thorough understanding of the business and financial circumstances which can generate tax concerns or opportunities, resulting in efficient, comprehensive tax advice while not compromising the integrity of the commercial arrangement.
Our tax lawyers also have a thorough appreciation of the interrelationship between financial accounting and taxation, with a keen understanding of the unique issues confronting public companies. Our experience includes expertise in counseling senior management, audit committees and boards of directors on matters relating to FAS 109 (Accounting for Income Taxes) and FIN 48 (Accounting for Uncertainty in Income Taxes) (ASC 740, Income Taxes), among other financial accounting issues. Our experience also includes the issuance of Circular 230 tax opinions for such financial accounting purposes, as well as for other transactional purposes.
The Tax Group also has significant experience in advising tax-exempt public charities, private foundations and other types of tax-exempt organizations on a wide variety of tax and operational issues, both on a pro bono and fee for service basis as the individual circumstance may warrant. This experience includes entity formation, the tax-exempt application process, and guidance regarding tax-exempt compliant operations, including issues concerning the recognition of unrelated business income. We also provide advice with respect to transactional issues in the tax-exempt context, including mergers, reorganizations and the structuring of joint ventures and management relationships between tax-exempt organizations and for-profit entities.
The Tax Group also has significant experience in private wealth and estate planning, including business succession, charitable giving, family wealth transfer planning and family office related issues.
The Tax Group also has extensive tax controversy experience, including tax examinations and administrative proceedings before the Internal Revenue Service and state and local tax regulators and other administrative authorities as well as judicial proceedings in both federal and state courts.