Whether you are an international or multinational entity, you can depend on our decades of experience advising on international tax issues and providing ongoing counseling to help you minimize your tax burdens, both in the United States and abroad. We have considerable strength in structuring cross-border acquisitions, dispositions, restructurings and joint ventures; exploiting (including through licensing arrangements) intellectual property with foreign partners and affiliates of U.S. persons; as well as the structuring and formation of offshore private investment vehicles (including private equity and hedge funds and their general partners, managers and advisors). We even provide tailored advice in regards to transfer pricing, private equity, all elements of fund formation, including all tax issues related to funds, carried interest and management incentives.

We understand that all types of investment funds, including hedge funds, require assistance with everything from planning to formation to operations. This is particularly true when it comes to handling all tax issues that may have ramifications on the funds themselves, partners and advisors.

Whether you are a domestic or off-shore fund, a fund utilizing parallel fund structures, master-feeder structures, or fund-of-funds arrangements, we can leverage our significant experience representing investors, investment funds and large financial institutions in connection with business, legal and tax considerations associated with all types of financial products – forward and futures contracts, swaps, notional principal contracts, options, equity-flavored debt instruments and other derivative transactions – for the benefit of your business. To further minimize the tax costs associated with the formation, structuring and operation of investment funds, we make it a priority to work closely with our corporate, private equity and real estate colleagues, to be sure that we’ve identified and addressed all of the possible issues and challenges that could arise and impact you.

If your business has elected to be treated as a regulated investment company or mutual fund, we can advise you on taxable and tax-free mergers, related reorganizations, and acquisitions of portfolios held by additional RICs and common trust funds. We can also help you meet the requirements for a mutual fund to qualify as an RIC for federal income tax purposes, including distribution and diversifications requirements. Our lawyers can even come to your aide regarding tax considerations in connection with utilizing RICs, publicly traded partnerships and other foreign and domestic entities as investment vehicles for a broad range of investment assets.

We provide tax planning advice that will help you structure your business operations and transactions to achieve the best possible tax results. We represent clients like you – publicly traded companies, private equity funds and their portfolio companies, to small start-up ventures – with many different types of small to large transactions and business arrangements. This includes the formation and capital structure of corporations, partnerships and limited liability companies, mergers, acquisitions, divestitures, tax-free reorganizations, tax-free spinoffs, joint ventures, and leveraged buyouts. We also represent lenders, issuers and investors with the tax aspects of financing transactions, including public and private debt and equity issuances, hybrid debt, true leases, capital leases, and synthetic leases.

You know that it is imperative that high net worth individuals prepare and plan for any personal tax issues or consequences, on an ongoing basis, in an effort to avoid tax-related disputes. We can provide this advice for you, if you are such an individual in need, regardless of your location of residence around the globe.

If you’re in real estate, you know that real estate transactions have unique tax considerations and consequences. We can assist you in structuring the acquisition, development and disposition of real estate, including Section 1031 exchanges and tax-deferred condemnations, and provide tax advice to buyers and sellers with respect to property tax and transfer tax issues associated with real estate transfers. We also represent investors (including private equity and institutional investors), developers and governmental agencies in structuring, drafting and negotiating partnership, joint venture and limited liability company agreements for single asset projects and real estate funds.

We serve clients like you, lenders, manufacturers, tax equity investors or developers involved in any manner of renewable energy transaction. We provide guidance with regard to energy and manufacturing tax credits, production tax credits and other tax-related benefits associated with such projects and bring significant experience with all financing techniques utilized in the renewable energy market, including partnership flip transactions, leases and inverted leases, and we can also help you with low-income housing credits, rehabilitation tax credits and historic tax credits. In particular, we even speak and write frequently on these very issues before professional associations and industry groups.

We have extensive experience representing taxpayers like you – Fortune 100 corporations, other business organizations, and individuals and tax-exempt organizations (such as universities, hospitals and trade associations) – in tax controversies with the IRS, the various state and local taxing authorities, even in criminal tax matters. We can represent you during audit and administrative appeal proceedings, as well as in federal and state courts at trial and appellate levels, including the United States Supreme Court.