Together, our tax attorneys provide a broad range of services for property owners, businesses, and investors seeking to improve their tax positions. Our clients include high-net-worth individuals, private equity and hedge funds, and cross-border businesses and investors. The attorneys draw upon their combined extensive experience with and knowledge of corporate tax, partnership tax, international tax, and taxation of real estate transactions to help clients structure transactions, property ownership, and investments to minimize the tax effect of such arrangements.
Corporate Tax
- Structuring and formation.
- Compensation issues (including IRC sections 280G and 409A).
- Mergers and acquisitions (both tax-free and otherwise).
- Financial products (debt, equity, and hybrids).
Partnership Tax
- Structuring and formation.
- Equity and compensation arrangements.
- Mergers and divisions.
- Capital structures.
- Change of ownership.
Taxation of Real Estate Transactions and Ownership
- Tax-free like-kind exchanges.
- Capital-gain maximization.
- Ownership structures.
- Tax aspects of real estate finance.
- Real estate investment trusts (REITs).
- Development, redevelopment, and repurposing.
International Tax
Inbound
- Foreign investment in U.S. funds (minimize the risk or cost of effectively connected income).
- Foreign businesses creating U.S. operations.
- Tax treaty considerations.
- Financing considerations.
Outbound
- Structuring overseas operations for U.S. businesses or U.S.-owned businesses.
- Deferral, foreign tax credits, tax-favored income, and use of tax treaties.
- Intellectual property considerations.