RCCB’s Tax practice offers sophisticated U.S. and international tax planning and tax controversy services to middle-market companies, investors, executives and individuals, as well as businesses engaged in transactions.

Many clients seek our advice when their business or personal affairs cross the border. These clients rely on us to help balance tax efficiency and tax risk management with their business, investment, or personal goals. To those clients, we offer practical advice, so that they can focus on their business instead of managing their tax affairs, while also avoiding tax traps and tax inefficiencies inherent in international business.

We also represent clients in federal tax controversies. Our track record includes successfully obtaining eight-figure tax refunds for corporate clients in tax litigation, as well as representing individuals through the difficult issues inherent in owning undisclosed foreign assets. In tax controversies, we think strategically to accomplish our clients’ goals.

Finally, because tax is an integral part of most transactions, such as mergers & acquisitions, we work closely with our Corporate & Business and Private Client Services Groups to advise on the tax structuring of their transactions.

FEDERAL TAX CONTROVERSY

We represent our clients in federal tax disputes. Our experience includes:

  • Pre-return filing advice

  • Administrative practice before the IRS (audits and appeals)

  • Litigation in U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Courts

INBOUND TAX PLANNING 

We help foreign companies and individuals invest in the U.S. market, including:

  • Organization of a U.S. taxable presence, in branch or subsidiary form

  • Tax planning for cross-border intercompany agreements, including licenses, debt instruments, management agreements, and other arrangements

  • Pre-immigration and post-emigration advice for individuals

OUTBOUND TAX PLANNING

We help U.S. companies as they seek to expand into international markets. Our outbound tax planning services include the following:

  • Outbound IP and other business migrations

  • Permanent establishment risk for foreign activities

  • Subpart F and PFIC planning for cross-border businesses and investments

  • Repatriation planning for cash trapped abroad

  • Implementation of IC-DISCs

TRANSACTIONAL TAX ADVICE AND STRUCTURING 

We work closely with our Corporate & Business and Private Client Services Groups to help plan business and personal transactions. Common planning issues include:

  • Tax structuring for mergers and acquisitions, and debt and equity financings

  • Reviewing and drafting allocations and distributions for partnerships, limited liability companies, and other pass-through entities

  • Preparing tax disclosure in fund formation documents

  • Implementation of ESOPs to provide tax-advantaged exits for owners of closely-held businesses

  • Employee compensation issues for growth and middle-market companies, including:

    • Option plans

    • Profits interest plans

    • Phantom equity plans

UNDISCLOSED FOREIGN ASSETS

We have guided over thirty U.S. taxpayers through the complex issues related to foreign assets that have not been disclosed to the IRS. This service includes:

  • Strategy and risks for disclosing assets to the IRS, including:

    • Offshores voluntary disclosures

    • Streamlined filing procedures

    • Delinquent FBAR and information return procedures

  • Negotiation with foreign banks and advisors to gather records and appropriately allocate liability for penalties

  • Repatriation or planning for foreign assets after disclosure

  • FATCA compliance


Team

Newsroom

Publications
  • Publication, Bloomberg , March 25, 2022
  • Publication, RCCB Employment Alert, March 20, 2021
  • Publication, RCCB Employment Alert, June 3, 2020
  • Publication, RCCB Tax Alert, May 2020
  • Prospective Tax Planning in a Down Economy
    Publication, RCCB Tax Alert, April 2020
  • COVID-19 Tax Alert
    Publication, RCCB Tax Alert, April 2020
  • Opportunity Zone Latest Developments
    Podcast, Federal Bar Association Tax Law Conference, March 2020
  • Qualified Opportunity Zones: What You Need to Know About Investing in the Zone
    Podcast, Philadelphia Bar Association, February 2020
  • Nuts and Bolts of Opportunity Zones and Qualified Opportunity Funds
    Speaking Engagement, American Bar Association , January 2020
  • Common and Complex Case Studies and Real-World Issues With Opportunity Zones as Qualified Opportunity Funds
    Speaking Engagement, American Bar Association 2020 Mid-Year Meeting, January 2020
  • Where Do We Stand on Qualified Opportunity Funds
    Speaking Engagement, American Bar Association Tax Section Fall Meeting, October 2019
  • The Best Estate and Financial Planning Topics
    Speaking Engagement, New York State Society of CPAs
  • Applying Integrated Estate, Financial and Asset Protection Planning
    Speaking Engagement, Virginia Society of Certified Public Accounts
  • Publication, American Bar Association, July 2019
  • Qualified Opportunity Zone: Investments After the April 2019 Proposed Regulations
    Podcast, Pennsylvania Bar Institute, June 2019
  • Seminar Series: Qualified Opportunity Zone
    Podcast, Montgomery County Development Corp., March 2019
  • What You Need to Know About Investing in the Zone
    Speaking Engagement, Qualified Opportunity Zones, February 22, 2019
  • Qualified Opportunity Zones – Reboot
    Publication, American Bar Association Tax Section Mid-Year Meeting, January 2019
  • Publication, American Bar Association, January 2019
  • Qualified Opportunity Zones - What Are the Rules?
    Podcast, Pennsylvania Bar Institute, January 2019
  • Opportunity Zones – What’s All the Buzz About?
    Speaking Engagement, 10th Annual High Net Worth and Family Wealth Conference, December 2018
  • Qualified Opportunity Zones 
    Podcast, Philly Living/Keller Williams, November 14, 2018
  • Seizing “Opportunities” to Create and Invest in Tax-Favored Qualified Opportunity Funds
    Publication, RCCB Tax Alert, August 2018
  • Tax Comments on Proposed Fractions Rule Regulations
    Publication, American Bar Association, March 2018
  • What the New Tax Law Means for Lawyers and Law Firms
    Speaking Engagement, Philadelphia Bar Association, March 2018
  • Tax and Accounting Update
    Speaking Engagement, Private Equity CFO Association, January 2018
  • Integrated Estate, Financial and Asset Protection Planning
    Speaking Engagement, Pennsylvania Institute of Certified Public Accountants
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