Sophisticated Tax Planning for Individuals and Corporations

IRS and state/local tax audits and controversies.

Tax Court litigation.

Counseling private foundations and public charities in their formation and obtaining and maintaining tax exempt status.

Handled planning, operation and Federal tax examination of off-shore captive insurance company. Planning involved the possibility of registering the off-shore company in various states, and the transfer of its business activities to an office in the United States. The planning and tax examination for this company involved Subpart F of the Internal Revenue Code. Successfully defeated National IRS position.

Represented the acquiring company in a tax-free merger of two computer companies.

Organized limited liability companies for closely held real estate businesses.

Advised and represented client before the IRS with respect to the payment of compensation to its executive-shareholders. The client was in the food distribution industry. Matter resulted in maintaining compensation treatment for majority of the payments to the executive-shareholders.

Represented substantial real estate company during a Federal examination of its returns. Matter progressed from the agent, to the IRS Appeals Office and, finally, to the United States Tax Court. The issue involved in the case related to an inconsistent position maintained by one of the partners with respect to the allocation of losses, nonrecourse liabilities and the application of Treas. Reg. §1.704-1(b)(2)(iv)(f). Matter resolved predominantly in favor of client, with relatively insignificant economic cost.

Represented public companies before the Internal Revenue Service in connection with the examination of corporate income tax returns. These clients were involved in various industries such as: steel manufacturing; gold mining; soda and beverage production and distribution; fast food restaurants; national hotel franchise operation; contract servicing operations; engineering; and real estate. In various matters, hundreds of millions of dollars in tax savings were produced.

Represented public companies before various state tax departments such as: New York, New Jersey, Pennsylvania, Ohio, Michigan, Utah, Alaska and California.

Generally, researched tax matters involved in business transactions and assisted corporate counsel in executing same.

New York

Kentucky

United States District Court, Southern and Eastern Districts of New York

United States Tax Court

United States Court of Claims

United States Court of Appeals, Second Circuit