TAX PLANNING
“Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes.” Helvering v. Gregory, 69 F.2d 809 (1934), aff’d, 293 U.S. 465 (1935)
Our tax planning practice draws upon our extensive tax controversy and business tax experience to devise and deliver the most creative, pragmatic and optimal solutions for our clients. Whether a transaction or operation is foreign or domestic, inbound or outbound, virtual or actual, taxable or tax-free our tax attorneys are ready to assist in formulating, negotiating, opining on, and drafting the most efficient structures and transaction flows available.
Our tax attorneys have extensive experience in advising, negotiating and opining on:
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Choice of entity matters
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Entity formation
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Due diligence
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Goodwill planning
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Ownership
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Restructurings
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Joint ventures
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Exit Strategies
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Optimal transaction matrix
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Business expansions
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Mergers&Acquisitions (M&A)
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Reorganizations
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Consolidated returns
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e-commerce transactions
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Intercompany arrangements
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Transfer Pricing
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Tax Treaties
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Controlled foreign corporations (CFC)
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Passive foreign investment
companies (PFICs) -
Permanent establishments
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Branch profit tax
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Portfolio interest
We pride ourselves on shrewdly counseling our clients about the tax implications and planning opportunities for all types of transactions with the primary goal of achieving optimal tax treatment consistent with business and personal objectives. Whether your transaction involves the establishment of a new enterprise, a business expansion, a complex merger, or the transfer of tangible or intangible assets, our attorneys have the experience and knowledge needed to analyze, structure, negotiate, document and close the deal.
Our Tax Planning practice includes the following sub-components:
