Taxation Planning for Business Operations
We frequently work in tandem with the firm’s corporate attorneys to help structure transactions such as mergers and acquisitions (both taxable and nontaxable); direct stock and asset acquisitions; foreign and domestic joint ventures; real estate matters including syndications, transactions relating to real estate investment trusts, like-kind exchanges, sales and dispositions of property as well as condemnations and other involuntary conversions; and other commercial and investment transactions including sales, leases, exchanges, financings and workouts. Our tax planning services also extend to issues surrounding business and entity formations, distributions, redemptions, reorganizations, spin-offs, liquidations and structuring transactions for raising capital as well as partnership, limited liability company and S corporation taxation issues. For clients engaged in international transactions, investments and business operations, we address the taxation issues likely to be encountered both in the country where the party undertaking the transaction is domiciled and the country or countries to which the transactions may also have a connection. Our attorneys are knowledgeable of the required integration of the complex foreign tax provisions contained in the Internal Revenue Code and regulations promulgated by the Internal Revenue Service with the tax treaties negotiated with various foreign countries that govern foreign companies that are parties to international transactions.
For cross-border transactions, we have advised clients on structuring the transaction as well as counseled clients on related issues such as advance and transfer pricing arrangements; issues and considerations under applicable tax treaties; controlled foreign corporation (CFC) issues; inversion planning and avoiding inversion issues; foreign tax credits, foreign tax credit impacts and limitations; withholding tax; and tax compliance obligations.
Taxation Planning for Individuals
We also advise individuals with complex, multinational issues to help them navigate through the myriad of tax laws in the United States as well as counsel them on the U.S. income and transfer tax impacts of personal planning and investment, including investments in real property, commercial businesses, service companies, hedge funds and private equity funds, among others. We also counsel clients on offshore investments, such as investments in passive foreign investment companies and joint ventures with foreign partners, as well as on structuring business investments outside of the United States.