Tax, Trusts & Estates
Corporate Tax & Reorganization
The choice of entity, and whether to operate as a C corporation, S corporation, limited liability company, partnership or sole proprietorship, requires careful analysis of the facts, circumstances and objectives of our clients for this fundamental decision.
Tax structure is a critical part of business planning and often has a major impact on the success or failure of a business venture.
A critical component of your business planning
From entity formation, through operations, and liquidity events such as sales, redemptions or liquidations, we can provide you with advice on all aspects of federal, state and local tax planning for businesses.
Comprehensive and creative advice
We provide counsel on the tax aspects of a wide variety of business transactions including acquisitions, sales, joint ventures, financings, bankruptcies and liquidations. Our tax lawyers seek involvement from the beginning of the transaction, when planning opportunities are most flexible, and work closely with you, your accountants and our corporate lawyers. This includes creatively planning a structure and drafting and negotiating the operative provisions of complex business agreements including purchase and sale agreements, merger agreements, joint ventures and partnership agreements. We also advise in connection with the federal tax consequences of international transactions, both in bound investment in the United States, and out bound investment overseas. We provide careful analysis of alternative structures, including without limitation tax free reorganizations and tax deferred arrangements, to maximize value.
When appropriate, we provide assistance with transactional compliance issues including filing elections with the taxing authorities. We also routinely work with our clients’ accountants on the proper reporting of transactions that we have structured or encountered.
Outside of the transactional area, we also provide advice in connection with Tax Controversies. This may include working with your accountants at the inception of an audit, or subsequently pursuing a disagreement through the administrative layers within the state or federal tax authorities and then through state or federal court review and appeals. We also advise clients on voluntary disclosure procedures to minimize penalties and criminal exposures.
- Estate and Income Tax Planning
- Wealth Preservation (NINGs, DINGs, SLATs, GRATs)
- Special Needs Planning
- Special Purpose Trusts
- International Estate & Tax Planning for Non-Citizen U.S. Residents
- 1031 Exchange
- Qualified Opportunity Zone Program
- QSBS Planning
- Tax Residency: Snowbird Counsel
- Estate and Trust Administration
- Business Succession Planning
- Corporate Tax & Reorganization
- Tax Controversies
- IRS & State Tax Collection Defense
- Sales & Use Tax
- Tax Investigations and Defense
- IRS & State Voluntary Disclosures & Compliance
- International Tax
- Trusts & Estates Litigation, Guardianships and Fiduciary Counseling