Practice Areas
Business Law
Executed a corporate risk audit that identified and mitigated numerous errors in the minute books and corporate filings.
Managed split-off transaction to separate business into two entities as part of a partner litigation settlement.
Designed and negotiated convertible debt issue for the sale of a financial product book of business to an existing partnership.
Created a partner equity compensation arrangement to incorporate new partner equity compensation to an existing partnership.
Tax Controversy Law
Mitigated several failures to withhold on royalty payments from an unincorporated U.S. business to several international licensees.
Resolved IRS challenge to client’s Health Savings Account withdrawals during the desk audit. Favorably resolved IRS challenge of an investment fund’s hedge identification method at the exam level.
Successfully obtained extension of time for company to make corrected entity classification elections. Consulted with a small CPA firm on the proper treatment for a disqualifying disposition of incentive stock options.
International Law
Designed and implemented structure to import and distribute products internationally, including setting-up legal entities, customs and VAT registration, making banking introductions, and providing logistics services introductions for warehousing and shipping.
Created inbound acquisition structure for foreign fund investing in U.S. real estate to eliminate withholding taxes on current income, provide a means for reinvestment of net income, and eliminate withholding tax on the repatriation of proceeds from the sale of the real estate.
Conceived and implemented plan for sale of business assets to maximize foreign tax traits under several future business scenarios.
Mitigated substantial embedded current year withholding taxes for a foreign private equity investment in a U.S. partnership while preserving the economics of the original investment plan.
Mergers & Acquisitions
Created tax economics model for private equity fund for use in their projections for acquisition projects.
Designed plan to aggregate numerous company assets, performed due diligence on assets to be sold, and worked with banks to auction assets.
Created slate of acquisition structures with fixed price implementation to allow private equity fund to acquire numerous assets and small companies, reduce professional fees, and lock in acquisition costs.
Structured and executed a real estate joint venture agreement with different allocations for two classes of investor interests and an active manager member.
Designed a multi-jurisdiction acquisition structure that minimized taxes, planned for the movement of cash, and minimized exit taxes.
How we work
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Booking
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Assistance
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Delivery
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