Transactional Tax Planning

Tax planning should never be an afterthought. Our Tax attorneys work in close partnership to ensure that every transaction is structured to maximize tax benefits while achieving the client’s business objectives. Our team approach brings efficiency to the process, while ensuring that important tax implications are never overlooked.

We provide comprehensive services to clients that range from small, family-owned businesses to large, publicly traded companies in virtually every commercial sector. For businesses that are just getting started, we examine the tax advantages and disadvantages of various entity structures, including corporations, limited liability companies, partnerships, joint ventures, syndications and trusts. For established companies, we provide a wide range of transactional tax services, including those related to:

  • Domestic and international corporate reorganizations, mergers and acquisitions
  • Real estate-related transactions including forming, operating and dissolving real estate ventures and real estate investment trusts
  • Structuring and executing like-kind exchanges, and tax planning for leaseholds
  • Obtaining the low-income housing tax credit and the rehabilitation tax credit
  • The full range of international matters, including inbound and outbound investments and specific experience in IC-DISC formation
  • Transfer pricing matters
  • Formation of partnership, LLC, S corp, and other pass-through entities
  • Purchase and management of aircraft, watercraft and specialized assets
  • Formation of nonprofit entities and joint ventures
  • Foundation and trust formation
  • Formation and operation of nonprofit entities and joint ventures between nonprofit and for-profit entities
  • Tax planning for financially-troubled businesses and real estate ventures
  • Requesting rulings from the IRS National Office regarding any of the above matters

In addition to crafting efficient structures for immediate transactions, we continually monitor changes in tax law to enable our clients to make smart decisions about the future. At every stage of development, our attorneys work to understand our clients’ goals and develop tax structures that work for their businesses.

Practice Category

  • Represented clients in the creation and structuring of funds, including a $250 million private equity fund; fund squeeze-outs of founders; and all aspects of corporate, partnership and LLC transactions – roll-ups, divisions, acquisitions, and both taxable and tax-free reorganizations.
  • Represented client in the structuring, drafting and negotiation of complex private equity transaction and hedge fund agreements, including alternative investment vehicles, investment by domestic entities, direct foreign owners, and indirect owners through blockers.
  • Represented worldwide group of large institutional investors on hedge and private equity investment fund investments with an aggregate value of $1 billion.
  • Represented client with unwinding of fund totaling $120 million.
  • Represented client in the structure of multibillion dollar partnership combination of two private enterprises.
  • Represented fund and other clients with structuring of acquisitions totaling several billion dollars.
  • Represented clients in spinoff of private construction/manufacturing/oil conglomerate worth several hundred million dollars.
  • Represented aviation company with presale structuring preparation and incorporate deal in anticipation of tax-free reorganization valued at $150 million.
  • Represented $300 million privately held companies – construction, manufacturing and petroleum – with restructuring and reorganization (with spinoffs, etc.).
  • Represented a $150 million privately held mineral and ranching company with restructuring, ancillary partnerships, and advising with respect to tax-free spinoffs, estate planning, and migration out of C corporation status.
  • Represented a $180 million privately held aviation enterprise with presale preparation and proposed restructuring, including integrated estate and charitable planning.