Tax

Our skilled Tax team brings strategic legal solutions to the often intricate tax challenges our clients experience with federal, state, local, and international tax issues. Our transactional tax experience ranges from entity selection and fund formation, M&A, restructurings and recapitalizations, including debt restructurings inside and outside of bankruptcy, capital markets offerings, real estate, and pass-through entity structuring advice, intended to mitigate the client’s income and non-income tax liabilities. 

We also answer important non-income tax questions, including those involving withholding, excise tax, sales and use tax, gross receipts tax, franchise tax, and property tax issues.  

Coupled with deep domestic tax expertise, our firm’s tax lawyers have extensive cross-border tax experience and knowledge. Through carefully considered tax planning and structuring strategies, our firm’s tax attorneys aim to mitigate any cross-border tax leakage scenarios. Similarly, we help many non-U.S. companies manage their U.S. federal, state, and local tax obligations.

In addition to our Tax team’s transactional tax experience, we are formidable advocates in the face of tax controversy, dispute resolution, litigation and appeals. Our approach to problem-solving when it comes to tax controversy reflects the combination of our substantive knowledge of applicable tax principles and an understanding of the special assessment, determination and collection procedures applicable to tax cases, including the unique courts and tribunals involved in the process. We have tried tax disputes before the U.S. District Courts, the U.S. Tax Court and state courts and tax tribunals, as well as the Internal Revenue Service and state tax authorities, including taking cases to higher federal and state appellate courts. 

Our Tax practice, in conjunction with the firm’s Private Client Services practice, also advises on the tax consequences of wealth transfers to benefit future generations, which may include resolving an array of estate and fiduciary tax matters along with personal tax and private wealth planning.