Practice Areas
Taxation
Tax considerations are an important part of business and personal transactions. Tax planning and structuring are critical in multinational business transactions, business succession planning, establishing new business ventures, and dealing with estates, gifts and trusts. We advise clients in planning to minimize federal, state and local taxes.
REPRESENTATIVE TRANSACTIONS:
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- Structure multinational business operations to minimize worldwide tax liability, including licensing, manufacturing, distribution, fulfillment and payment, and royalty streams.
- Maximize available tax incentives for specific industries and in specific jurisdictions.
- Provide Private Placement Life Insurance (“PPLI”) to shield assets from creditors, achieve income tax and estate tax benefits and provide anonymity of ownership for businesses in the United States and U.S. Companies doing business abroad. PPLI programs attain maximum tax benefits under the laws of the client’s domestic jurisdiction and the jurisdictions in which the client does business.
- Structure Captive Insurance Companies (Domestic and International) to achieve cost savings, income tax and estate planning benefits.
- Structure and negotiate joint venture transactions, including choice of entity, choice of jurisdiction, formation of entities, document operating provisions, payout structure and other transaction terms.
- Tax planning in restructuring of mortgage debt.
- Structure mergers, acquisitions and financing transactions to maximize tax benefits.
REPRESENTATIVE TRANSACTIONS:
- Represent long-term real estate investment clients in purchase, sale and financing of commercial real estate, § 1031 like-kind exchange and subsequent renovation and leasing of medical tower and office space.
- Structure tax and investment program for real estate development projects. Establish and operate private placement life insurance programs for tax beneficial business programs.
- Structure licensing programs for optimum tax benefits and compliance with intellectual property laws in multiple jurisdictions.
- Advise employment structuring for U.S. taxpayers employed in foreign countries and foreign residents obtaining employment in U.S.