Tax laws can be complex and financial consequences steep. Knowledgeable counsel can provide a significant advantage in effectively navigating complicated tax matters of all types – formation, transactions, dispositions, litigation and multi-jurisdictional operations.
Our tax attorneys continue a long firm tradition of providing sophisticated tax services to our clients in the U.S. and throughout the world. We strive to provide our clients with proactive counseling and strategic legal solutions, counseling on a broad range of tax services, which include:
- Tax Planning for Business Transactions and Operations (United States)
We represent clients in all aspects of tax planning for business transactions and operations. We provide effective tax services to all phases of a business, from start-up to disposition. Our clients include publicly traded corporations, corporate joint ventures, and privately financed growth businesses.
We provide tax planning for a wide variety of business transactions and operations, including mergers, acquisitions, dispositions, joint ventures, real estate transactions, spin-offs and other corporate separations, corporate formation, and financing. We are experienced in a full range of tax issues arising under all areas of United States Federal income tax law.
We also provide a wide array of tax services for establishing and operating a variety of entities seeking special tax treatment, including real estate investment trusts (“REITS”), real estate mortgage investment conduits (“REMICs”), regulated investment companies (“RICs” or mutual funds). We assist with structuring entities for beneficial tax treatment and addressing myriad operational issues that arise in acquiring, managing and disposing of the entity’s assets.
- Tax Administration and Litigation (United States)
We represent clients in all phases of IRS, state and local audit proceedings, and regularly obtain favorable settlements of proposed audit adjustments in administrative proceedings. We guide clients through tax litigation when an acceptable IRS administrative settlement cannot be reached. When necessary, we assist clients in obtaining advance rulings from the IRS’s National Office confirming the tax results of proposed client transactions.
- Transactional Tax Planning and Advice (Cross Border, Non-U.S.)
As the world becomes a smaller place to do business, implementing a tax efficient structure to operate and finance operations among competing tax systems becomes increasingly complex. We provide a wide array of sophisticated tax services that help our clients minimize their worldwide tax costs. We assist in the structuring of a wide variety of U.S. inbound and outbound transactions, including tax planning for expanding operations, acquisitions and joint ventures, off-shore financing techniques, and cross-border securities offerings. We are experienced in all major aspects of U.S. Federal income taxation of inbound and outbound U.S. transactions, as well as a number of non-U.S. tax systems.