We help align your business with your legal and tax structure to achieve the optimal tax result. This includes: (i) tax planning advice for businesses, (ii) tax structuring and documentation for business transactions, and (iii) international tax.
Tax Planning
Our tax planning services include:
- structuring equity compensation to minimize tax liability,
- maximizing the tax benefit of business losses,
- structuring business for token sales and initial coin offerings (ICOs), and
- structuring companies to maximize the tax benefit from the new pass-through tax deduction under Section 199A.
We can help businesses that want to lower their taxes in response to tax reform; to maximize the tax benefits of exit payments to retiring partners or LLC members; or want to structure an expansion, a sale of a business division or any other change to a business.
Transactions
Tax planning for transactions includes mitigating tax risk for buyers and sellers in M&A transactions, structuring tax-efficient sales and acquisitions of companies (including LLCs, S-Corporations, C-Corporations and foreign corporations), and the tax aspects of joint venture agreements. Representative transactions include:
- Advised a variety of companies on the domestic and international tax aspects of initial coin offerings (ICOs).
- Represented private equity fund on tax issues in its acquisition of a late stage startup software company serving the hospitality industry.
- Advised software and technology company in building materials industry on tax aspects of the acquisition of strategic technology target.
- Represented U.S. controlling shareholder of Swiss pharmaceutical company treated as “Controlled Foreign Corporation” on complex partial sale and partial merger transaction with UK pharmaceutical company.
- Counseled private equity fund on tax aspects of its acquisition of an international technology and accounting services group for the hedge fund industry.
International
We routinely advise businesses on a variety of international tax issues, including:
- the sale and acquisition of foreign corporations by U.S. businesses;
- inbound investments by foreign corporations making portfolio investments or strategic acquisitions in the United States; and
- the tax aspects of outbound cross-border and international transactions by U.S. taxpayers.
