The optimal tax structure must work in concert with the business objectives and economic realities of the transaction. Our attorneys focus on identifying the client’s goals and in understanding the circumstances of the parties in the transaction. This direct communication enables our advice to be practical yet valuable. The globalization of the economy has resulted in an ever-increasing number of cross-border transactions, both inbound and outbound. Particular attention is paid to the international tax aspects of a structure because transfer pricing, treaties, withholding taxes and the additional complexity associated with such transactions. Our emphasis on understanding a client’s circumstances early in the engagement enables our advice to be a comprehensive and effective, while permitting the transaction to close in a timely manner.
Our clients consist of sophisticated individuals, family-owned businesses, REITs and closely-held entities. Any advice rendered to an individual should be consistent with an efficient estate plan. In family and closely-held settings, it is important to document the relationship among the participants in an agreement that addresses death, disability, voluntary withdrawal, valuation and resolution of management issues. Equally important is the focus on liquidity in estate planning as the business typically represents a substantial portion of the taxable estate. A consistent theme is the requirement that the guidance provide an efficient exit strategy from the structure. We represent clients in a diverse number of industries from virtualization, manufacturing, real estate development and management of real estate owned. We welcome the opportunity to discuss such matters with you.