Overview

We counsel a wide variety of clients, from Fortune 500 companies and multinational corporations to privately held businesses. We advise and represent clients in business transactions and financings, tax controversy and litigation, legislative and regulatory activities, executive compensation and tax planning, international taxation, state and local taxation, and foundation and exempt organization matters. We represent a full spectrum of clients ranging from publicly held corporations, financial institutions and pension plans to closely held corporations, partnerships and nonprofit organizations.

Our group includes former members of the IRS, CPAs and tax lawyers admitted to practice before various courts including the U.S. Tax Court, the U.S. Court of Federal Claims, the U. S. District Courts, U.S. Circuit Courts of Appeal and the U.S. Supreme Court.

We have helped our clients structure transactions that permit generation of so-called "Section 1603 grants" as well as energy tax credits. We have also helped clients achieve state and local tax incentives for investing in energy projects.

Transactions, Financings & General Tax Planning

Our Transactional Tax Practice has substantial experience in taxable and tax-free mergers and acquisitions, international tax planning, tax-exempt organizations, corporate and partnership tax, like-kind exchanges, executive compensation and state and local taxation. We represent a full spectrum of clients ranging from publicly held corporations, financial institutions and pension plans to closely held corporations, partnerships and nonprofit organizations.

Representative Services
  • We structure mergers, acquisitions, joint ventures and other strategic alliances.
  • We obtain private letter rulings from the IRS National Office, often on a very expedited basis, on complex transactions such as spin-offs and tax-free reorganizations.
  • We counsel clients on the use of sophisticated financing vehicles such as securitizations.
  • We provide independent reviews of tax products marketed by accounting firms and investment banks.
  • We design and implement executive compensation arrangements, such as deferred compensation plans, stock options and other equity-based incentive plans and golden parachute agreements.
  • We assist clients in reducing state franchise and sales taxes through creative multistate tax planning.
  • We assist educational and charitable entities concerning their federal and state tax issues.
Tax Controversy 

Our Tax Controversy Practice focuses on handling taxpayer examinations and other contested matters for clients around the country. Our practice has grown dramatically over the past 15 years and has included among its clients one of the world’s largest telecommunications companies, some of the nation’s largest financial institutions and brokerage firms, a major airline, major utilities, large national retailers, many multinational corporations and some of the nation’s largest real estate developers. We have also represented large privately held business entities in such industries as real estate, fast food, distribution, automotive and health care.

Our Philosophy & Approach

Our philosophy is to present our clients’ cases to IRS Examination and Appeals or to a court through simple, direct arguments carefully supported by the most relevant facts and persuasive authorities. We view our role as providing the decision makers (IRS Revenue Agent, IRS Appeals Officer, judge or jury) with the facts and authorities necessary to understand and resolve or decide the issues in the tax controversy. This strategy has helped us win major concessions at IRS Examinations/Appeals and significant victories in the courts.

In approaching each case, we know the degree of success is dictated by more than just aggressive advocacy. It involves understanding client-specific protocols, expectations and objectives for resolution of the tax controversy. Addressing these at the outset enhances our effectiveness and increases our chances for success.

Protocols

Determining how you prefer to work with us is a key starting point. Understanding the most efficient manner of communication, billing requirements and procedures, and critical success factors is important in establishing a solid foundation for us to work together effectively and efficiently.

Expectations

Understanding your parameters for success and their relative importance is key to how we apply our strategy and manage your tax controversy matter. We work with you to understand both your legal, business and accounting (e.g., "FIN 48") issues as they relate to the individual tax controversy matter at hand.

Goals

Each client has its own unique goals when faced with a tax controversy matter. We work closely with you to define, understand and help you achieve your desired outcome. Whether it’s standing on principle or precedent, obtaining a quick ruling or settlement, or minimizing taxes and/or penalties, we assist you every step of the way in meeting your goals.