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Entity Selection and Federal Tax Classification
Because most state law or foreign law entities are eligible to select and change their default classification for federal tax purposes, we advise and assist on entity selection and formation, and we...
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IRS National Office Practice
We are frequently retained by clients or their advisors to obtain private letter rulings, technical advice, and other administrative guidance from the Internal Revenue Service.
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Estate Planning and Estate Administration
Our role as tax counsel for our client's business and investment interests provides an advantage for implementing an estate plan or administering an estate administration. Every client...
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Pre-Controversy Tax Advice and Counsel
Our lawyers combine litigation and substantive tax experience to assist clients in anticipating and planning for future controversies. The ultimate resolution of a tax dispute is influenced...
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Tax Audit Representation
In complex audits, we identify significant issues, develop key audit strategies, provide advice in responding to information document requests and summonses, establish procedures to identify and...
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Joint Ventures, Partnerships, and Limited Liability Companies
We advise and assist clients conducting business and investments throughout the life cycle of partnerships, limited liability companies, and other flow-through entities.
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Corporations
We advise and assist clients on corporate tax matters throughout the life cycle of a business, including the formation, recapitalization, merger, restructuring, disposition and liquidation of...
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Administrative Appeals
Many of our tax controversy clients come to us immediately before or after the completion of the tax audit. At this stage, we prepare and submit a comprehensive written protest to a proposed...
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Civil Tax Litigation
While we always seek to avoid the time and expense of litigating tax controversies, sometimes the only way to vindicate your position is to go to court. We have no hesitancy in turning to...
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Mergers and Acquisitions
We advise and assist with tax efficient domestic and international mergers, acquisitions, divestitures, and restructuring of businesses, including corporate spin-offs. When appropriate, we...
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