Our Practice Groups

Tax

Our Tax group draws on a wealth of experience representing financial institutions, fund sponsors, and strategic company clients of all sizes and across all major industries, in domestic and cross-border transactions, to provide creative, tax efficient solutions to complex tax problems and challenges.

Our Tax group is an essential part of our firm’s overall practice. Our tax professionals seamlessly integrate with all our other practice groups in our firm to address overall tax planning as well as tax issues that arise in various matters. In addition, we regularly advise clients on standalone tax projects, serving as a destination practice area. Our Tax group draws on a wealth of experience representing financial institutions, fund sponsors, and strategic company clients of all sizes and across all major industries, in domestic and cross-border transactions, to provide creative, tax efficient answers to complex tax problems and challenges.

The Tax department’s areas of concentration include, among others, M&A, private investment funds (such as private equity, venture, and hedge funds), international tax, venture capital and private equity investments, credit and finance, real estate related tax planning, and tax controversy work. 

In the mergers and acquisitions area, tax consequences for buyers, sellers, and lenders often drive the structure and form of a transaction. Our tax professionals are skilled in assisting clients in understanding the sometimes complex tax alternatives available to the parties in structuring an acquisition and, consequently, choosing the right solution for that particular transaction. The Tax department is involved early in the transaction process and we strive to design and implement tax-efficient planning from the start. Our tax professionals have prepared and received private letter rulings from the Internal Revenue Service and local tax authorities on many tax issues, including spinoffs. Moreover, our tax professionals have advised clients as to the benefits of alternatives to spinoffs such as tracking stock. 

In the private investment fund area, our tax professionals have broad experience in representing all relevant parties (including sponsors, investors, and anchor investors) and have worked with funds from formation through dissolution (and sometimes clawback). As a result, tax issues (such as UBTI, ECI, and waived management fees) are anticipated and resolved before they become problems.

For a variety of reasons, many businesses are no longer conducted in the traditional corporate form. Businesses are conducted as partnerships, limited liability companies, Subchapter S corporations, Qualified Subchapter S Subsidiaries, branches, and other forms. Our Tax department regularly advises our clients on the benefits and detriments of these alternative forms of doing business, as well as the tax consequences of buying, selling, and merging these entities.

In the real estate area, our tax professionals are actively involved in the financing and refinancing of real estate projects. These transactions often raise the intricate provisions of partnership taxation, cancellation of indebtedness, and local transfer tax issues. We often advise offshore investors regarding the various methods for investing in United States real estate and the relative advantages of each method. Moreover, our tax professionals are familiar with the complexities of the various forms of like-kind exchanges available to defer real estate gains.

Our international tax focus cuts across the firm’s practice groups. Our tax professionals regularly work on international tax issues surrounding acquisitions with offshore buyers, sellers, or target companies. Similarly, our tax professionals regularly advise sponsors, investors, and funds that are foreign in the private investment fund area. Our tax professionals often “quarterback” a select group of local tax advisors in various foreign jurisdictions to provide our multinational clients with exceptional cross-border solutions.  

Our tax professionals regularly publish articles in professional journals on tax topics and are often quoted in the public media regarding tax issues. In addition, members of the Tax department have taught business and tax classes in local law schools and universities and frequently make presentations at conferences for legal, business and accounting professionals.