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  • Tax planning for businesses and individuals
  • Tax dispute resolution
  • Wealth transfer and estate planning and administration

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Tax and Estates

Our goal in the Tax and Estates Group is to help our clients determine the route that will reach their objectives with a minimum tax burden. Together with our colleagues in various practice groups throughout the firm, our lawyers work with clients to identify and execute the most tax-efficient solutions available for their unique needs. Business owners considering expansion or sale of their businesses, parties settling lawsuits, families establishing wealth transfer plans and estate administrators all rely on the significant experience of our lawyers across multiple tax disciplines to identify overlooked opportunities and creative solutions.

As skilled listeners, we ask questions and carefully evaluate the needs of our clients in order to formulate effective tax savings strategies. Our lawyers are well-versed in several subdisciplines, hold advanced degrees, and have years of experience in both government and the private sector. This depth allows us to assist a range of clients, from management teams considering corporate transactions and families considering complex estate planning matters, to the personal representatives of an estate navigating challenging waters.

We understand that the nuances of business transactions can be complex, and pride ourselves on our effective communication to provide clarity to our clients. We advise closely-held businesses, entrepreneurs, large corporations and their shareholders, non-profit and tax-exempt organizations, partnerships, limited liability companies, S corporations, trusts, estates, family offices and multi-generational families. We also regularly collaborate with private equity funds, investment bankers, financial, accounting and other professional advisors.

We provide practical legal solutions related to:

  • Business formation and choice of entity
  • Taxable and tax-free mergers, acquisitions and divestitures
  • Real estate transactions, including Section 1031 like-kind exchanges
  • State and local tax planning
  • International taxes, including investment structuring, treaty issues, and transfer pricing
  • Executive compensation, including non-qualified deferred compensation plans
  • Charitable giving and tax-exempt organizations
  • Individual estate and income tax planning
  • Wills, trusts and elder law planning
  • Estate and trust administration and probate litigation
  • Tax dispute resolution

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 to later 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, and 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.

Representative Matters

Tax

  • Worked with the owner of a privately held business in its acquisition by a private equity firm while deferring a significant portion of the owner’s gain from the ‘sale’ of such business
  • Worked with a number of clients to qualify for and utilize state income tax credits to minimize their overall tax burden and improve the bottom line
  • Worked with numerous board of directors and other business owners to create equity incentive compensation plans for key employees that provided significant income tax benefits, including deferral of the recognition of income 

Estate Planning and Administration

  • Represented a family of a closely-held family business in designing the transfer of the business to the 5th generation, by designing a transaction structured as a sale which did not yield income taxes and shifted ownership to the next generation without incidence of the gift tax
  • Represented numerous clients in designing trusts and other arrangements for their family members that have special needs in order preserve assets, and allow the beneficiary to continue receiving the greatest level of support from other private and public sources

Dispute Resolution 

  • Represented a family business in a multifaceted IRS audit that resulted in a settlement in U.S. Tax Court where the multi-million dollar assessment was substantially reduced.
  • Resolved multiple IRS audits on issues ranging from R&D tax credits, hobby losses, and depreciation adjustments, often with little or no adjustments.
  • Represented numerous clients in state and federal voluntary disclosure programs (including failing to report foreign bank accounts) avoiding hundreds of thousands in penalties, and reducing additional taxes and interest that would otherwise be payable to taxing authorities
  • Successfully represented a multi-state bank in administrative proceedings, as well as before state appellate courts including the state Supreme Court, challenging a state tax assessment of several hundred thousand dollars

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