Clients engaging in complex commercial transactions require creative and sophisticated tax advice to meet their immediate goals and to be in a position to easily adjust to changing laws and new opportunities.
- Assisted during the last twelve months with the tax structuring, negotiations and planning in connection with hundreds of acquisition, disposition or refinancing transactions, as well as associated integrations, restructurings and rationalizations.
- Designed integrated global structures by creating tax-advantaged holding companies and intellectual property holding companies. Our legal services required evaluation of the tax-efficient capitalization plans for each business and plans for substantial Subpart F expansions into Europe by one of the largest U.S. privately-held companies and a significant Internet-based company.
- Represented the family owners of a top retail products company in connection with the sale of their company to a public company, structuring the sale so as to give the client cash along with stock and diversify their portfolio with a significant holding of public company stock.
- Obtained IRS rulings on a multitude of domestic and international corporate, financial product, and tax accounting issues in connection with public and private transactions.
- Structured or restructured numerous multi-national groups in connection with acquisition and disposition transactions.
- Obtained favorable rulings from the IRS National Office on various transaction and structuring issues.
- Negotiated joint ventures and limited liability company agreements with developers, pension funds, and venture capital funds.
- Secured a research tax credit in the amount of $25 million on behalf of a regulated public utility.