TAX
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.
OUR CAPABILITIES:
- Tax Equity Financing: 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).
- Partnership & Corporate Taxation: 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.
- International Tax Planning: 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.
- Real Estate Taxation: 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.
- Tax Controversy & Compliance: 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.
- Transaction Tax Structuring: 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.