Tax

Overview

Companies are looking for strategic partners to offer clear and decisive answers to their tax questions. We provide clients with effective and practical guidance in tax matters both routine and novel.  Our clients include domestic and multinational businesses, as well as nonprofit organizations, estates, trusts, and individuals—and we tailor our advice to each specific situation in corporate or financing transactions, partnerships and joint ventures, state and local tax planning, or litigation. Our attorneys have the experience and breadth of knowledge to help clients meet their business objectives.

Representative Experience

• Large public utility: Successfully navigated the IRS’ “no-rule” list to obtain a follow-on private letter ruling (20-plus years after their original ruling) to enable a corporate restructuring for the client
• Reorganized retailers: Represented the clients regarding private equity acquisition and tax aspects of restructuring
• Fortune 100 company affiliate: Represented the client regarding SALT nexus issues related to telecommuting
• UK private equity funds: Advised numerous funds regarding US tax aspects to investors, including setting up blocker companies, avoiding US permanent establishment status, and counseling on effectively connected income
• Chinese consumer product manufacturer: Helped to identify an appropriate transfer pricing expert, and worked with that expert to create a simple transfer pricing study to satisfy the client’s documentation requirements
• Plaintiff in IRS suit: Represented client in the US Court of Federal Claims seeking a $40 million income tax refund, which the IRS refuses to pay
• Manufacturer’s management group: Represented the management group of a tool manufacturing company in $1 billion sale to a private equity firm, including elaborate management earn-out LLC and rollover structure
• Mid-market strategic funds: Represented several funds acquiring “S” Corporation targets to manage their tax exposure through a combination of corporate restructurings, ”F” reorganizations, RWIs, and tiered escrow arrangements
• Foreign and tax exempt investors: Represented clients in formation of many private REITS for private equity funds planning

Recognition

Nationally ranked for Tax Law by U.S. News “Best Law Firms” in 2015–2020.