Income Tax

We have a robust income tax practice and provide services in a variety of areas.  In many cases, we work with attorneys from other practice areas, including Commercial Real Estate Law, Corporate Law and Mergers & Acquisitions, Venture Capital and Private Equity, Family Wealth Planning, and Estate & Charitable Planning.

Transactional

We help structure 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 perform tax due diligence.

Operational

We provide advice on operational tax aspects of businesses, including incentives, state and local tax planning, accounting methods, and tax reserve opinions.  We also assist in rationalizing sales and use tax burdens for multi-state businesses.

Administrative

We obtain tax rulings from federal, state, and local tax authorities, including private letter rulings from the Internal Revenue Service, and income and tax rulings from state tax authorities.  We have also filed single and multi-state voluntary disclosure agreements for both sales and income tax issues.

Controversy

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.

Recent Work

  • Helped a private company re-structure its operations to minimize phantom income and rationalize its flow-through of tax benefits.
  • 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.
  • Structured a leveraged blocker arrangement for a private equity fund to facilitate foreign investment.
  • Obtained a favorable resolution of a variety of issues for a corporate taxpayer at the IRS Appeals division.
  • 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.

Helped a US company structure its acquisition of several UK businesses and then integrate these operations in a tax-efficient manner.