We have substantial experience in assisting our international and domestic clients to select the most appropriate and efficient entity structure with which to make their investments or conduct their business.  We advise our clients on entity structure selection from tax and business perspectives, with an eye toward limiting tax costs and preserving tax attributes

Our counsel includes the tax implications surrounding the formation of limited liability companies (LLCs), permanent establishments, branches, partnerships, joint ventures, C corporations, S Corporations, consolidated returns, trusts, hybrid and other structures. We also advise on the tax implications of various debt and equity capital structures, portfolio interest exception and other business financing alternatives. Our practice further counsels partners, shareholders, trustees and beneficiaries, and regularly negotiates and crafts agreements among and between owners, shareholders, key employees, and other parties.

Subsequent to formation and through the life-cycle of the organization, we provide general transactional and tax compliance advice, including in connection with expansions, treaty-based return positions and the tax impact of events occurring prior to implementation. We have significant experience in reviewing existing accounting methods used and, where necessary, in representing clients seeking Internal Revenue Service (IRS) consent to change to a more favorable method.