Attorneys in our Tax group are involved in all aspects of the firm’s transactional practice and can draw upon their experience in corporate law, mergers and acquisitions, state and local tax issues and other related areas to provide both creative and practical solutions for clients. We structure tailored, economic solutions to our clients’ tax needs, whether for routine tax audits and appeals or for foreign tax planning and tax litigation. Our clients include public corporations, financial institutions, domestic joint ventures, new business ventures, non-profit organizations and individuals. We represent traditional manufacturing and service businesses, high-tech businesses, real estate developers, health care companies, sports teams, national banks and many others. We often provide critical advice regarding the fundamental structuring of major transactions in order to help our clients develop the optimal structure to achieve the financial results they seek.
Partnerships, Limited Liability Companies and S Corporations
Our corporate and tax attorneys work closely with clients, advising them with respect to general and limited partnerships, as well as limited liability companies and limited liability partnerships that are classified for tax purposes as partnerships. Our clients include closely-held entities, such as S corporations, family and development partnerships and limited liability companies. We provide counsel to clients that have elected S corporation status or are classified as disregarded entities for tax purposes. We advise them with respect to compliance and planning.
We have extensive experience with disguised sales, restructurings and sales, tax disputes, debt finance allocations and the tax effects of contributing or distributing appreciated property from partnerships and limited liability companies. We also structure complicated economic arrangements that involve special allocations of income and loss and multiple classes of ownership interest.
Venture Capital and Private Equity
Our venture capital and private equity attorneys regularly work with our tax specialists to help clients acquire start-up and established companies and form private equity funds. Our expertise is also required when tax exempt entities are investors and unrelated business taxable income may result.
We help with the structuring of portfolio company acquisitions, especially when complicated economic arrangements exist, including structures granting management profit interests in the venture. We work with attorneys in our bankruptcy group and other practices to structure acquisitions of companies in work out situations and deal with issues such as forgiveness of debt income.
Real Estate
Members of the group assist our real estate attorneys with matters such as:
- Acquisition and development of real property, including tax advice regarding the structure of ownership entities and transactions.
- Financing of real property assets, including mortgage loans.
- Sale/leasebacks.
- Sales.
- Like-kind exchanges (including tenant-in-common arrangements).
- Other dispositions of real estate assets.
We also assist in the restoration of historic buildings and their conversion into residential condominiums.
