Tax

Corporate Tax, International Tax, Tax Controversy, Tax-Exempt Organizations and Private Foundations

Tax

Our tax lawyers use their in-depth knowledge and experience to help our clients achieve their business goals and objectives in the most tax-efficient manner. With more than 20 tax lawyers located in multiple offices in the United States and abroad, we have the depth and experience to serve as strategic business advisers to our clients in a wide variety of U.S. and cross-border transactions and tax controversy matters.

We focus on delivering practical and tangible solutions to clients for the challenging tax issues they face and provide our best assessment of the risks each potential tax strategy would take to achieve its goals. We are upfront in providing our assessment of the probability of success of various strategies, as we believe clients need that type of information to make informed decisions. We are also business lawyers, so we are keenly aware that while spotting tax issues is important, the development of solutions drives the ability to evaluate and close transactions. We also believe that our knowledge base, contacts and research skills enable us to arrive in a timely manner at as many potential and practical solutions as reasonably possible. We represent a variety of clients, from small start-ups to large public companies, as well as nonprofit organizations, entrepreneurs and high-net-worth individuals.

International Tax

Over the past several years, our tax lawyers have counseled clients in transactions involving more than 100 countries. Our tax group regularly provides sophisticated and effective counsel on the full array of cross-border transactions. Our international team of tax lawyers provides both the depth and efficiency necessary for creative and tax-friendly strategies on the local, state, national and international levels. We routinely and effectively handle important and complex tax controversies for our clients, and our approach has consistently produced excellent results at trial and, even better, in settlement.

Our international tax practice focuses on providing innovative and practical solutions in all phases of cross-border tax work, including:

  • Cross-border mergers and acquisitions
  • Structuring transactions to avoid the inversion rules
  • CFC and PFIC analysis and planning
  • Planning for multinational corporations
  • Inbound investment in the United States by foreign investors and, in particular, foreign investment in U.S. real estate
  • Outbound investment in foreign jurisdictions by United States private equity funds
  • Upstream investment fund structuring for foreign investors in United States funds
  • Optimizing global tax structures
  • Intercompany cross-border debt
  • All aspects of FATCA compliance and planning
  • Foreign tax credit planning

Corporate Tax

Our tax team works closely with our corporate team to create innovative and tax-friendly solutions for our clients at the earliest possible stage of each transaction. Our depth and breadth of experience enable us to assist a variety of corporate entities, including public, privately held, mid-sized, start-up, “S” and “check the box” companies, in many different types of transactions, including:

  • Corporate acquisitions
  • Tax-free reorganizations
  • Restructurings
  • Stock offerings
  • Debt financings
  • Mergers
  • Spin-offs, split-offs and split-ups
  • Leveraged buyouts

Partnership and LLC Tax

Our lawyers have in-depth knowledge of all aspects of partnership taxation and extensive experience in addressing the myriad of business issues that our clients face in connection with the formation and operation of pass-through entities. We routinely assist clients in selecting the most advantageous type of pass-through entity through which to conduct their business activities and in drafting and negotiating the applicable operating agreements. In all instances, our lawyers leverage their knowledge and experience to provide innovative and tax-friendly Public Offerings/Public Reporting solutions that are consistent with our clients' business and economic objectives.

Federal and State Business Tax Issues

Our tax lawyers deliver practical and tax-efficient solutions for the challenging tax issues clients face at both the federal and state levels, and we provide our best assessment of the risks that each potential strategy would take to achieve its goals.

Taxability of Settlements

In connection with our federal and state litigation practice, it is fairly common for our clients to want us to review, analyze and, in appropriate situations, work with the litigation team to improve the tax efficiency of a potential settlement.

Employee Compensation Tax Issues

We advise public and private entities in all areas of employee benefits and executive compensation, and we are often recognized as their “in-house outside counsel” in these matters. Our experienced team delivers the practical and useful counsel that our clients need, especially in this heavily regulated area where rules are constantly evolving. Our group routinely provides advice and guidance necessary for clients to properly construct and administer various plans, as well as to take full advantage of the operational, financial and tax benefits that the law allows. We provide counseling on all aspects of executive compensation, including analysis of deferred, equity and incentive compensation issues, such as tax consequences of tender offers related to repriced stock options.

Tax Controversies and Litigation

When our clients have disputes with taxing authorities, they turn to our tax controversy team, which has extensive experience representing businesses and individuals in both civil and criminal tax controversy matters. We have represented taxpayers in hundreds of federal and state tax controversies. While we have substantial litigation experience and are determined to formulate and advocate the strongest defense strategy for our clients, in most cases and, where possible, we seek to resolve our clients’ conflicts with the taxing authorities early enough in the process to avoid litigation. We also have extensive experience representing clients in federal and state tax audits, the appeals process, refund litigation proceedings and more.

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