Taxation
Corporate – advice on stock and asset reorganizations, divisive
reorganizations, formation and liquidation of corporations, reallocation
of income, constructive dividends, accumulated earning taxes, S
corporation status, deduction for reasonable compensation. employment
taxes.
Partnerships – allocation of income, deductions, tax credits,
formation, operating distributions, liquidations, opinions on tax status
of partnerships.
Foreign Taxation – advice to foreign investors on tax consequences of
investment in the U.S.; application of U.S. and foreign tax treaties;
application of subpart F to controlled foreign corporations; outbound
transfers to foreign affiliates; intercompany pricing; U.S. withholding
on outbound transfers; foreign tax credits.
Exempt Organizations – tax issues relating to exempt status of
charitable organizations, related exempt foundations, (including
reorganization of tax exempt organizations); private inurement issues;
charitable annuity and unitrusts, pooled income funds, advice on
charitable giving.
State and Local Taxation – advice and litigation relating to state
and local income, franchise and sales and use taxes, gross receipt
taxes, ad valorem taxes.
Audit and Litigation – representation before the IRS. Louisiana
Department of Revenue and tax litigation in Federal and state courts.
Estate Planning
All aspects of Federal and Louisiana estate and gift tax planning,
including preparation of wills and trusts; valuation discounts; probate
proceedings, estate and gift tax audits and litigation in Federal and
state courts.
Employee Benefits
Design and implementation of qualified plans (pension, profit
sharing, target, thrift, ESOP and 401(k), including IRS, DOL and PBGC
compliance), deferred and key executive compensation arrangements
(excess benefit plans, executive compensation plans, qualified and
non-qualified stock options, restrictive property transfers, rabbi,
secular trusts, golden parachute payments, split dollar insurance) and
welfare plans (self insured and group life, health and disability), tax
exempt organizations, professional corporations and partnerships and
ERISA litigation (defense of claims asserted against insured and
self-insured health and disability plans, qualified plans, breach of
fiduciary duty, prohibited transactions, and pre-emption of state laws).
(Board Certified Tax Law Specialist, Louisiana Board of Legal Specialization)