Tax and Estates

Tax

Our lawyers assist clients with issues including federal, state, local and international tax planning and the formation, operation and liquidation of various business entities. We stay abreast of the changing tax landscape and advise our clients accordingly, keeping their business interests at the forefront. Ultimately, our goal is to develop practical approaches that are consistent with individual and business objectives while reducing the overall tax burden whenever possible.

Working closely with clients, their other professional advisors and lawyers in other disciplines at the firm, we structure and implement taxable and tax-free business and investment transactions involving individuals, corporations, partnerships, limited liability companies, S corporations, trusts and estates.

Our business planning experience includes business entity transactional work, including formation, acquisition, mergers and disposition, transfers of businesses to succeeding generations as well as executive compensation across a variety of industries. We also employ experience in international business to advise on cross-border transactions as well as business and tax structures for U.S. investments abroad as well as foreign investment in the U.S.

Estate Planning and Administration

Our lawyers guide individual clients and their families through all phases of estate and wealth transfer planning, accommodating long-term objectives while being sensitive to current needs. With sophisticated knowledge and understanding of federal and state taxation, we devise plans that allow for the passage of wealth and assets across multiple generations while minimizing the transfer tax burden. We counsel young families with early stage planning as well as those with significant assets, including the ultra-high net worth, in all cases focusing on protecting and preserving family assets. We also advise individuals on ownership succession for closely-held businesses both during lifetime and by testamentary devise.

We take a collaborative approach to private wealth management, both in our internal structure and in our client relationships. Ensuring thoroughness and accessibility, each client is introduced to the appropriate lawyers and paralegals within the group to ensure that the client’s needs are fully and timely addressed. Additionally, we regularly partner with our clients’ other professional advisors, including accountants and investment managers, to create highly tailored and tax-efficient plans unique to each client’s specific needs and desires.

As part of our estate planning practice, we have developed significant experience in the design and use of irrevocable life insurance trusts, qualified personal residence trusts, family limited partnerships and limited liability companies, charitable remainder trusts and private foundations, generation-skipping trusts, grantor retained annuity trusts, and other sophisticated estate and income tax savings techniques. Our experience includes tax audits with the Internal Revenue Service and dealings with the Art Advisory Panel, Charities Bureau of the Attorney General’s Office and various Surrogate Courts.

Dispute Resolution

Our lawyers regularly represent clients before various administrative agencies and courts, including the Internal Revenue Service, U.S. Tax Court, state and local taxing authorities and numerous state probate tribunals. We have represented clients before the IRS and state taxing authorities in defending a variety of tax return positions. We also have successfully navigated the complex procedural issues presented by advance ruling requests, tax audits, administrative appeals, and tax litigation. In addition, we have significant experience in representing clients with offshore account disclosures, including the IRS Disclosure Programs and the state counterparts.

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