Due Process Appeals(DPA) & Tax Court Litigation
Investment Adviser Act; Investment Company Act of 1940
IRS Competent Authority Procedure
Mergers & Acquisitions Global Tax Planning
On tax due diligence, we identify historical, ongoing and potential risks and plan tax optimization strategies, assess the amounts and risk probabilities, and advise on the tax aspects of acquisition and purchase agreements, minimize transaction taxes and post-closing tax liabilities.
On tax structuring: we design and elaborate on tax efficient structures for acquisition and purchase transactions, advise and design tax efficient gain repatriation, carve-outs and exits. We review and summarize tax positions, anticipate transaction structuring, achieve ongoing and post-closing tax efficiency. We review and advise on U.S. tax reform, Tax Court and appeal court tax rulings. We provide advance comfort, and clarification on pre-closing carve-outs, tax treatment of sales proceeds and gains, transaction taxes and repatriation taxes.
Securities Law Compliance
Tax Efficient, Structured Transactions
Loan and capital investment structuring, international tax planning.
Global tax planning for multinational companies, funds and individuals, especially with regard to U.S. immigration related tax planning, risk assessments.
Tax Treaty Arbitration
Trusts & Family Trust Fund Formation
“Happy families are alike,” they plan family trust funds, wealth and estate transfer well. To counsel and advise on family trust and estate matters, we apply in-depth, thorough reading of State trust law statutes, case and common law, US tax code, Treasury Regulations, Tax Court case law and applicable treaties.
In addition to following the developments and ongoing reform of US tax law, we endeavor to be well-versed on leading State trust law jurisprudence (including Alaska, Delaware, South Dakota and Wyoming).
We draft all forms of trust documents (Charitable Trust, Dynasty Trust, Family Trust, GRAT, ILIT—Life Insurance Trust, etc.). We design and implement tailored, individual wealth and estate planning trusts.
We identify and help to implement strategies for minimizing transfer taxes—including gift, estate and generation—skipping taxes; respond to and address clients’ specific planning needs—including transactional planning and structuring, complex inter-generational wealth transfer, trust asset protection and distribution planning strategies.