We offer our clients sophisticated and comprehensive tax counseling for the planning, negotiation and implementation of corporate and commercial transactions of all types. We handle tax litigation in all jurisdictions, including federal and state courts, as well as administrative proceedings.
In particular, international transactions require complex tax and fiscal decisions, which often make the difference between success and failure. We take unique pride in our specialized ability to counsel on the effect of U.S. tax laws and bilateral tax treaties on international transactions and to integrate our tax advice with fiscal planning on a global basis for clients seeking to extend their reach into, or beyond, the United States.
Our work has included:
- Tax planning for numerous overseas companies regarding the structure of operations in the U.S., including the consideration of issues such as permanent establishment, capitalization, transfer pricing, employee compensation and social security tax liability issues
- Tax planning in connection with mergers and acquisitions, including asset and stock purchases
- Counseling with respect to the employment-related tax impact of starting business operations in the U.S., including the effect of and upon foreign pensions and U.S. social security
- Tax planning for manufacturers in connection with income from overseas distribution and retail business operations of affiliates
- Tax planning in connection with key employee stock options, stock grants, pension and deferred compensation plans
- Tax planning regarding the equity ownership and issuances of closely-held business entities and their owners, including valuation of the company and its equity for tax purposes
- Planned and implemented operational and financial structure for overseas multi-national corporate manufacturing group to minimize adverse foreign tax and monetary exchange impact in connection with the financing of overseas subsidiaries and the making of inter-corporate distributions
- Provided tax planning respecting stock ownership of closely-held family business, including use of incentive stock options and grants for shareholders, utilizing valuation of company shares and estate tax planning
- Planned and implemented organization of multinational corporate group to minimize multinational tax impact upon intra-group operations and financing
- Structured European jewelry designer and manufacturer’s U.S. distribution operations, including issues of permanent establishment of a trade or business, transfer pricing, capitalization, shareholder loan terms and employee compensation
- Advised closely-held U.S. manufacturer respecting tax considerations of executive/employee incentive stock options and stock grants in light of prospective initial public offering
- Advised computer services company on tax aspects, including deferred compensation issues, in connection with structuring of key executive stock option plan
- Analyzed estate and income tax impact of sale of commercial real estate parcel by executors of decedent’s estate