Federal and State Transactional Tax Planning

Our Tax Section attorneys assist clients in structuring and implementing business transactions, ranging from the relatively simple to the most complex and cutting edge, including the formation of new enterprises, acquisitions, dispositions, joint ventures, cross-border transactions, tax-free reorganizations, like-kind exchanges, investment capital raising and financing transactions. Further, we advise clients on choice of entity issues and have extensive experience in using pass-through entities (e.g., joint ventures) to structure business transactions. We also counsel clients on the multi-state tax implications of business transactions. In connection with our negotiation and planning of these transactions, we are often asked to issue opinion letters addressing the consequences of transactions. Our relationships with tax administrators assist us in obtaining informed guidance on administrative practice in gray areas through discussions with the IRS and/or the state taxing authorities. We also assist clients in obtaining formal written guidance, such as IRS private letter rulings, when needed.