We provide tax advice on the structure of acquisitions, dispositions, and other transactions to maximize tax efficiencies. We have expertise in corporations, partnerships, S corporations and trusts, and advise on both inbound and outbound transactions. We also provide tax diligence review.
Estate Planning and Business Succession
We provide assistance on succession issues for large, privately-held businesses, and focus on both income and estate tax consequences of such changes. We also assist high net-worth individuals in connection with residence trusts, family limited partnerships, and grantor trusts.
We provide advice on operational aspects of businesses, including state and local tax planning, accounting method changes, and tax reserve opinions.
We obtain tax rulings from federal, state, and local tax authorities, including private letter rulings from the Internal Revenue Service, and income and sales tax rulings from various states. We have also filed single and multi-state voluntary disclosure agreements for both sales and income tax issues.
We handle federal and state tax audits, from initiation through administrative appeal to litigation. We provide a range of involvement, depending on the client’s needs: for some clients, we provide only strategic advice, for others we review all auditor requests and obtain all response materials. We have experience in corporate, partnership and individual tax audits.
We helped a private company re-structure its operations to minimize phantom income and rationalize its flow-through of tax benefits.
We helped a U.S. company re-structure its European operations and obtained several foreign tax rulings to make its withholding and VAT obligations more efficient.
We obtained a favorable resolution of a variety of issues for a corporate taxpayer at the IRS Appeals division.
We obtained an accounting method change for a taxpayer to make its state income tax obligations more efficient.
We helped a technology company reorganize its operations to rationalize its state and foreign tax obligations.
We helped a US company structure its acquisition of several UK businesses and then integrate these operations in a tax-efficient manner.