Federal and International Taxation
We advise clients on minimizing potential tax liabilities on corporate acquisitions, dispositions, leveraged buy-outs, redemptions, liquidations and dissolutions. We are also involved in S corporation, limited liability company and partnership transactions including formations, dispositions and restructurings.
- Structuring domestic and cross-border mergers, acquisitions, divestitures and corporate restructurings.
- Structuring corporate, limited liability company and partnership organizations in the U.S. and offshore.
- Structuring corporate redemptions and restructurings.
- Structuring compensation plans for employees including stock options, partnership equity options and carried interests.
- Corporate transactions under audit by the Internal Revenue Service.
- Structuring asset and stock acquisitions and dispositions to minimize tax impact on buyers and sellers.
- Drafting tax opinions for corporate transactions.
- Drafting and processing ruling requests involving corporate transactions before the National Office of the Internal Revenue Service.
- Performing tax due diligence for prospective buyers of C corporations, S corporations, limited liability companies and partnerships.
- Providing advice regarding the federal consolidated return rules.
- Representing taxpayers before the Internal Revenue Service and the Courts.