We work with our clients to plan transactions, mitigate exposure and ensure compliance across technical tax laws, regulations and ordinances. Our commitment to maintaining client service while ensuring analysis and promoting cross-functional interaction produces a team-oriented approach through which our we work closely with clients and colleagues to generate the best results specifically tailored to meet each client’s needs and circumstances.
Our attorneys are also experienced in other fields, including business law, family wealth planning and real estate.
Our services include:
Entity Structures and Business Transactions
We help clients solve problems and develop tax planning opportunities that meet the needs of their business through shareholder agreements, operating agreements, buy-sell agreements, incentive plans and other organizational agreements. Whether a client’s business is emerging, maturing, expanding or winding down, we are a one-stop-shop for operational and transactional matters, including the structuring of contracts, joint ventures, and other arrangements with customers and business partners, as well as mergers, acquisitions, asset sales, equity sales, securities issuances, reorganizations, divisions, exchanges, recapitalizations, workouts, syndications and other transactions.
We assist organizations with formational issues and in obtaining favorable determination letters, commonly in areas outside of the historical “box” of tax-exemption. We continue to serve more traditional tax-exempt organizations, including hospitals, health care systems, universities, museums, foundations, trade associations, business leagues and social clubs. The issues facing tax-exempt organizations are both distinctive and comparable with respect to their for-profit counterparts. To these ends, we assist with nuanced issues like unrelated business income tax, compensation, private foundation compliance, fiduciary duties, lobbying, solicitation and information reporting, as well as general issues like governance, joint ventures, mergers, acquisitions, reorganizations, consolidations and reclassifications. Our attorneys are skilled at helping tax-exempt organizations—new or old, straightforward or unique—navigate challenges and achieve their objectives.
Real Estate, Tax Credits, and Incentives
Drawing on cross-functional resources, our attorneys have a long-standing track record of advising developers, investors and lenders in various real estate transactions, including tax-oriented real estate financings, workout transactions, tax aspects of REIT formations, operations, mergers, acquisitions, and financings, in addition to tax credit transactions like federal and state low-income housing tax credits and historic tax credits. Our team combines their experience with our client-oriented focus to carefully navigate the rules and regulations surrounding these complex structures, while never losing sight of a client’s business goals and objectives.
Our attorneys include those with significant experience litigating matters at the federal, state, county and city levels, as well as with audits, protests, refund and abatement claims, ruling and determination requests, technical advice, closing agreements, and other matters related to assessment, levy, payment, and compliance involving the Internal Revenue Service, state departments of taxation, and other administrative bodies. Matters include defense of transactions and reporting positions, valuation issues, offers in compromise, and reasonable-cause-based abatements and relief requests. Through collaboration, we are able to work across the firm’s offices to find specialized experiences and to access litigators with experience at all levels of government.