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Practice/Industry Group Overview
Akerman Senterfitt provides tax advice and services to domestic and foreign corporations, partnerships, individuals, and not-for-profit institutions. We advise and represent clients with respect to all types of federal, state, and local tax issues, including business structuring, business acquisitions, mergers, restructurings and other reorganizations, executive compensation and employee benefits, real estate tax issues, international tax issues, estate and gift taxes, Florida state income, sales and other taxes, tax audits, and tax litigation. Our tax lawyers work closely with the firm's corporate and real estate lawyers to integrate tax solutions to match our clients' objectives.
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Services Available
Business structuring, mergers, acquisitions, and reorganizations
Our tax lawyers have extensive experience in structuring business entities and in processing business acquisitions, combinations, and reorganizations. This includes the following:
- The formation of corporations, partnerships, limited liability companies, joint ventures, business trusts, real estate investment trusts (REITs)
- Taxable and tax-deferred stock and asset acquisitions and mergers
- Business separations such as taxable and tax-free spin-off transactions
- Stock issuances and redemptions
- Debt restructurings and recapitalizations
- Like-kind exchanges
Executive compensation and employee benefits
The tax practice also includes the structuring and implementation of executive compensation and employee benefit plans, including the following types of plans:
- Qualified and non-qualified stock option plans
- Stock bonus plans
- Employee stock ownership plans
- Deferred compensation and pension plans
- Profit-sharing plans
- Severance plans and golden parachutes
- Cafeteria plans
We also advise clients with respect to audits of benefit plans by the IRS and the Department of Labor, planning of distributions and termination of plans, and supplementing retirement benefits through the use of charitable trusts, insurance planning, and other techniques.
International tax planning
The firm's international tax practice involves both inbound and outbound planning, which includes advising clients with respect to the following issues:
- Foreign withholding tax
- Branch profits tax
- Effectively connected income and taxation of real estate activities
- Application of international tax treaties
- U.S. estate tax and pre-immigration planning directed at diminishing the impact of U.S. taxes after the establishment of U.S. tax residency
- Deferral of U.S. taxation of foreign income
- Foreign tax credits
- Minimizing taxation on a worldwide basis
Estate and gift tax planning
We offer a substantial range of services to assist clients with estate planning and estate administration, including the reduction of estate, gift, and generation-skipping transfer taxes and related income taxes. Similarly, counseling is provided on family wealth transfers to accomplish tax-efficient transfers of interests in family-owned corporations, partnerships, or trusts. Click on "Capital Transactions" in the "Practice Areas" section of this website for special tax planning services offered to certain high net worth individuals.
Tax-exempt activities
We represent numerous tax-exempt organizations including hospitals and other healthcare organizations, Universities, and other educational institutions, governments, private foundations, charitable organizations, religious organizations, trade associations, business leagues, and political organizations. We also represent clients with respect to tax-exempt financing and low-income housing tax credit projects. We advise not-for-profit clients with respect to the formation and qualification for exempt tax status, and in the planning of transactions involving not-for-profit organizations to diminish the impact of unrelated business income taxes.
State and local taxes
Our state and local tax lawyers advise clients on strategies directed at diminishing the impact of Florida state income taxes, sales taxes, documentary stamp taxes, and other state and local level taxes. Beyond the typical range of tax services, our activities and strong presence in Tallahassee can provide clients with necessary technical support in both legislative and administrative arenas with regard to state taxes. We have lobbied successfully on numerous occasions for specific tax relief and favorable changes in Florida's tax laws and regulations relating to issues which specifically affect our clients.
Tax controversies
The firm's tax lawyers also represent clients in tax audits and tax litigation at the state and federal levels.
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Clients:
Bank of America, First Union, SunTrust Bank, AmSouth Bank, Wells Fargo, ; CitiCapital, Household Finance, Chrysler Financial, LLC, Honda Finance, Toyota Finance, Nissan Motor Acceptance
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Matter Experience
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Reported Cases |
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Chrysler Financial Company, LLC v. Indiana Department of Revenue, 761 N.E. 2d 909 (Ind. Tax Ct.), review denied (2002)
Chrysler Financial Company, LLC - predecessor to Daimler Chrysler Services North America, LLC
The Indiana Tax Court reversed the Indiana Department of Revenue's denial of Chrysler's refund claim and awarded Chrysler a sales tax refund in connection with bad debts arising from Chrysler's financing of motor vehicle sales.
, January 2, 2002
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Representative Transactions |
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Representative reported cases include: In the Matter of the Claim for Refund Under the Sales and Use Tax Law of WFS Financial, SR EAA 52-009479, Case ID 56535 (California Board of Equalization Dec. 14, 2000), December 13, 2000
Barnett Bank, N.A. v. Dept. of Revenue, Case No. 97-02375, Division CV-G, Fourth Judicial Circuit, Duval County, Florida (July 22, 1998)
, July 22, 1998
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Languages spoken by Taxation Professionals
Spanish, French |
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