Practices: Tax

The lawyers in our Tax Department have extensive experience with sophisticated, complex, and often unique federal, state, and international tax issues. We have structured, developed, and advised with respect to mergers and acquisitions, various debt and equity financings, mortgage-backed and asset-backed securitizations, leasing transactions, and financial products, including derivative based products. We regularly represent clients with respect to audits, administrative tax hearings, and litigation, and frequently secure private letter rulings.

The Tax Department works closely with all of our clients and continually services the tax needs of the other departments in the firm. We make a concerted effort to know and understand our clients and their businesses. Our lawyers regularly publish articles, present at various conferences and seminars, and teach law school classes dealing with a wide range of tax topics.

The range of our tax practice includes, but is not limited to, the following:

Structuring, and advising with respect to, tax-advantaged partnerships, many involving tiered partnerships and special tax allocations, including general real estate, low-income housing, equipment leasing, and scientific research;
Structuring, and advising with respect to, the tax aspects of joint venture agreements involving major insurance companies, banks, foreign investors, private developers, and tax-exempt organizations;
Structuring, and advising with respect to, transactions for general and limited partnerships, “C” and “S” corporations, limited liability companies, limited partnerships, real estate investment trusts (REITs), fixed and variable investment trusts, real estate mortgage investment conduits (REMICs), registered investment companies (RICs), “hub and spoke” structures, mutual funds, private foundations, public charities, group trusts, grantor trusts, taxable mortgage pools (TMPs) and individuals;
Structuring, and advising with respect to, tax-free exchanges, options, hybrid debt and other innovative techniques;
Structuring, and advising with respect to, public and private offerings and investments for domestic and foreign investors and taxable and tax-exempt entities to provide current income, tax deferral, and tax-exemption benefits;
Structuring, and advising with respect to, public and private offerings of asset-backed securities as well as stock and commodity pools;
Counseling partnerships and investors in partnerships on tax consequences of alternative workout arrangements;
Counseling, and advising with respect to, leasing transactions, including leveraged leasing, cross-border leasing, sales-lease back transactions, and municipal leasing;
Representing lenders, equity investors, lessors and leases in leasing transactions;
Representing partnerships, corporations and individuals in tax audits and controversies involving hundreds of millions of dollars; and
Counseling charities and donors on valuation issues and other aspects of planned giving.

Our lawyers have also:

Advised as to structure, negotiation and implementation of tax-free reorganizations and spin-offs, leveraged buyouts, taxable acquisitions and dispositions, recapitalization, restructurings, and liquidations;
Advised with respect to original issue discount, market discount and similar technical tax law issues, and preparation and review of tax disclosures and related legal opinions;
Performed sophisticated tax planning, including ruling requests and legislative rulemaking matters, and representation in tax audits;
Designed and advised on the taxation of financial products and derivatives, including credit derivatives, synthetic securities, interest rate swaps and money market fund eligible structured products, swaps, options, futures, hedging and various structured products;
Structured acquisitions of businesses by domestic and foreign investors;
Created tax-exempt organizations, including foundations; and
Represented various parties in seeking or controlling the levels of real estate taxation of a variety of commercial properties.