Taxation
The firm's tax practice is sophisticated, broad based, and dynamic -- covering all areas of the tax law, while keeping up with constant changes in the law and the latest tax saving strategies. Our tax lawyers advise clients who have come to the firm specifically for tax representation and also work closely with lawyers from the firm's other practice groups to develop the most tax efficient structure for each transaction.
Our areas of expertise include domestic and international mergers and acquisitions, recapitalizations and restructurings, real estate and natural resources, securities offerings, venture capital investments, and commercial banking transactions. Our international tax practice regularly advises foreign clients regarding the tax aspects of their U.S. operations and U.S. clients with respect to the tax consequences of their foreign activities.
Clients
Clients that have benefited from the firm's tax advice include public and private corporations, as well as pass-through entities such as limited liability companies, public and private partnerships, and subchapter S corporations. Our tax lawyers also advise individuals on sophisticated tax savings techniques such as equity swaps, like-kind exchanges, and other income deferral strategies.
The firm has counseled Fortune 500 corporations as well as small and mid-sized family-owned businesses, in each case developing tax efficient strategies tailored to the client's situation. For example, we have:
•advised a large U.S. computer and electronics manufacturer on the tax consequences of issuing hybrid redeemable convertible preferred stock;
•assisted a U.S. subsidiary and its foreign parent corporation — a major British household products firm — restructure their debt to take maximum advantage of the earnings stripping rules and tax treaties;
•reorganized several family-owned businesses to adopt more tax efficient structures and minimize taxes on the transfer of the business to the younger generation.
For Fortune 500 corporations as well as small and mid-sized family-owned businesses, we have developed tax efficient strategies tailored to the client's situation.
Tax Controversies
An important part of our tax practice is the representation of clients in tax controversies. We regularly advise and represent businesses and individuals in tax audits by the Internal Revenue Service and various state and local tax agencies. Our tax lawyers also work closely with lawyers from the firm’s litigation group to prepare cases for litigation in the Tax Court and other federal and state courts.
State and Local Taxation
As state and local governments have increasingly sought to expand their tax revenues, the firm's clients have more frequently looked to us for advice in state and local tax planning and to handle tax controversies with state agencies. Among other things, we have advised businesses on matters including corporate income and franchise taxes, sales and use tax, and property taxes and represented individuals in controversies over state residence.
Tax-Exempt Entities
The tax practice also provides advice to a number of public charities, private foundations, and other tax-exempt organizations. Our attorneys regularly counsel tax-exempt entities regarding unrelated business income tax (UBIT), and have provided innovative strategies for minimizing UBIT on charities' fundraising activities. We have also assisted tax-exempt entities in establishing for-profit subsidiaries and entering into joint ventures.