We have extensive experience in advising individual and business clients in all aspects of federal, state, local and international tax law.
Tax Advice and Planning
We regularly work with clients to develop tax-efficient structures for their business and real estate acquisitions, operations, restructuring and divestitures, including the use of pass-through entities such as partnerships and limited liability companies and real estate investment trusts. We assist foreign persons with respect to their US tax obligations, such as FIRPTA, and U.S. clients with respect to US tax filing and disclosure requirements and benefits relating to their activities abroad, including tax treaty issues. We also engage in income tax planning for both individuals and businesses.
Our tax advice services include:
- Drafting and review of partnership, buy-sell, compensation, asset sale, licensing and other agreements
- Obtaining “bulk sale” clearance for a business acquisition
- Drafting and negotiating private letter ruling requests
- Providing tax opinions on a wide variety of issues
Support Services for Other Attorneys
For Real Estate Lawyers: Submitting requests for FIRPTA “withholding certificates” on sales of US real property by foreign persons
For Matrimonial Lawyers: Quantifying tax and time value of money aspects of divorce settlements; unfiled returns; unpaid balances; requests for innocent spouse relief, and qualified domestic relations orders. When a divorce settlement calls for division of most “qualified plan” pension arrangements (not including IRAs), a court order must be obtained to instruct the plan to divide the pension benefits. There are many nuances to these documents, as they must be carefully tailored to produce the result desired by the client in a manner that will be approved by the pension plan and the court. It is important to get us involved early, to ensure that the parties agree to a division of the assets that will be approved by the plan after the judgment of divorce is signed. If not, the parties could have to re-negotiate and re-litigate the treatment of the pension assets.
Tax Advisory Sample Matters