Our Tax practice is able to guide corporations, partnerships, and high-net-worth individuals through intricate domestic and cross-border tax strategies. We can integrate technical tax law with real-world business considerations, ensuring our advice is pragmatic, forward-looking, and carefully aligned with operational goals.
To deliver sophisticated legal solutions with the agility, insight, and value that today’s businesses demand. We combine elite legal expertise with real-world business experience to solve complex challenges efficiently and effectively. Our attorneys are committed to understanding your business objectives, anticipating obstacles, and creating practical pathways to success.
Our attorneys have experience structuring transactions leveraging federal and state tax credits across various sectors, including renewable energy, film, and affordable housing. By employing vehicles like sale-leasebacks or partnership flips, we can help investors and developers optimize returns under evolving legislation (e.g., Inflation Reduction Act).
We have the expertise to advise on capital account maintenance, 704(b) allocations, and disguised sale rules for complex partnership arrangements. Our corporate tax capabilities span S-Corp and C-Corp formations, consolidated returns, and tax-free reorganizations to accommodate business growth or M&A opportunities.
With experience in GILTI, Subpart F, and cross-border M&A structuring, we can navigate global tax complexities to minimize risks and leverage tax treaty benefits. Our team can also handle reporting obligations like Forms 5471 and 5472, ensuring compliance at every step.
We are able to counsel developers, REITs, and fund managers on 1031 exchanges, FIRPTA compliance, cost segregation, and capital gain deferrals. Our solutions are designed to maximize after-tax returns without exposing clients to unnecessary risk.
From audits to appeals, we can defend clients before the IRS and state authorities with a strategic focus on resolving disputes efficiently. Our controversy capabilities include negotiating installment agreements, penalty abatements, and offers in compromise.
We can integrate tax analysis into M&A, reorganizations, and capital markets transactions, ensuring each deal captures the full benefit of available tax attributes while adhering to business objectives.