TAX
The Firm’s tax practice frequently involves working closely with the Firm’s corporate clients to resolve structuring, compensation, licensing and transactional issues in the most tax efficient manner. In addition, the Firm has been engaged by large financial institutions such as Morgan Stanley as special counsel to provide tax advice in particular specialized areas.
The Firm’s tax department brings over 15 years of experience in corporate and transactional tax planning and tax litigation-including specialized expertise in domestic and international merger and acquisition transactions, securities offerings, project financings, partnership and LLC structures, derivatives transactions, investment funds and offshore insurance companies. The tax department’s experience also encompasses the structuring of executive and incentive compensation agreements, procuring Internal Revenue Service private letter rulings and technical advice memoranda, and resolving tax disputes on behalf of clients. We also have extensive experience advising on tax issues relating to not-for-profit entities. Some of the matters in which the Firm’s attorneys have been involved include:
- Structuring of a large investment partnership to accommodate U.S. and foreign investment for a well-known biotechnology funds group
- Development of tax-advantaged financial products for a Canadian based investment bank
- Representation of a large publicly-traded corporation in connection with tax disputes arising out of the application of a tax sharing agreement
- Structuring of U.S. operations for a Swiss multinational software company
- Advising on optimum capital structure for an offshore insurance company merger
- Structuring master international licensing arrangements for a U.S. based materials company
- Development of a tax structure permitting ISO-like treatment of options issued by non-corporate entities
- Opining on the proper valuation methodology for distributions from a qualified defined contribution plan
- Providing periodic advice to a multinational investment bank on various retirement plan matters such as rollovers, minimum distributions, investment limitations and unrelated business taxable income