Overview
We work closely with businesses and individuals to identify practical solutions for critical tax issues related to important strategic objectives. Knowing that professional success and personal wealth are often closely intertwined, we also collaborate with lawyers in other practice groups, including corporate, estate planning and real estate, to help our clients maximize their overall tax benefits.
Our transactional tax lawyers are an integral part of each deal team, which enables us to focus on structuring and negotiating transactions to achieve our clients’ business objectives in a tax-efficient manner. We also counsel clients on the federal, state, and international tax issues arising from business transactions, such as:
- Capital gains issues arising out of investments in real estate
- Choice of entity and related tax consequences
- Cross-border transactions and international tax planning
- Development joint ventures
- Domestic partnerships and flow-through entities
- Equity incentive plans and stock options
- Establishing new business operations domestically and abroad
- Executive compensation
- Liquidations and stock redemptions
- Mergers and acquisitions including inbound and outbound cross-border deals
- Private offerings
- Property tax planning
- Real property acquisitions, dispositions and complex tax-deferred exchanges
- “S” corporation structuring and operations
- Tax-free reorganizations, including spin-offs, split-offs, and split-ups
- Taxable asset and stock purchases
Our Tax Controversy lawyers have extensive experience in dealing with federal, state, local and international administrative proceedings and controversies. These lawyers have represented clients before the Internal Revenue Service (IRS), Franchise Tax Board (FTB), State Board of Equalization (SBE) and various local and county jurisdictions. Our lawyers also are involved during the planning of a transaction to identify and minimize potential tax controversies. Our Tax Controversy attorneys have extensive experience representing clients in the following matters:
- Individual income tax audits and appeals before the IRS and FTB
- Entity income tax audits and appeals before the IRS and FTB
- Sales and use tax audits and appeals
- Payroll tax audits and appeals
- Foreign account and asset compliance through the Offshore Voluntary Disclosure Program
- Property tax appeals with the SBE
- County property tax controversies
- Audits of estate and gift tax returns