INTERNATIONAL TAX PLANNING:

  • Advised several US multinational businesses on international tax issues after Congress enacted the Tax Cut & Jobs Act in 2017, including on issues such as GILTI, Code Section 965, FDII, subpart F and PFIC planning.

  • Advises a renewable energy developer managed in Spain and the United States on cross-border tax planning for new projects.

  • Advised a $25 million Cayman Islands hedge fund on tax matters regarding its restructuring and redomestication into Delaware.

  • Advises several high-net worth families with US family members regarding estate planning and trust matters with respect to their worldwide assets.

  • Advises several Belgian companies in the craft beer industry on acquisitions and expansions within the United States.


TAX CONTROVERSIES:

  • Won Gateway Hotel Partners, LLC et al. v. Commissioner,T.C. Memo 2014-5 (Jan. 9, 2014), a case involving the federal tax treatment of state historic rehab credits earned by a real estate partnership, after a trial in the U.S. Tax Court.

  • Won Colorcon, Inc. v. United States, 110 Fed. Cl. 650 (2013), a case involving the tax treatment of a $191 million settlement payment, at the summary judgment stage.

  • Resolved dozens of IRS tax disputes for companies and high-net worth individuals at the IRS audit and appeals level.

  • Represented over 100 taxpayers in voluntary disclosure matters of offshore foreign assets.


TAX CONSULTING ENGAGEMENTS:

  • Assists companies with minimizing tax through choice of entity structuring, including analysis of Code Section 199A tax benefits, QSB tax benefits, and related foreign tax consequences, as well as minimizing tax consequences of changing choice of entity.

  • Advises a privately held business on aviation-related tax matters related to personal and business travel on company aircraft.

  • Advised a local golf club on tax matters in connection with a uniquely structured sale of land and 97 social memberships to a real estate developer, who will build townhomes on the land and issue the social memberships to townhome purchasers. The purchase price was $9 million plus possible incentive payments.


MERGERS & ACQUISITIONS:

  • Advised an Israeli target and leading manufacturer of pipe couplings, grips, and clamps on tax matters related to its sale to a U.S. public company $140 million in cash.

  • Advised a manufacturing company on tax matters related to its $91 million sale to a private equity buyer.

  • Advised a healthcare company on tax matters in connection with a $66.5M leveraged buyout of the company by a private equity buyer.

  • Advised a private equity backed national courier and logistics company on tax matters in connection with its strategic acquisition of another national courier and logistics company for consideration in excess of $40 million.

  • Advised the seller of a national telecommunications services company on tax matters in connection with the sale of the company for $26 million to a private equity buyer.