The firm has a diversified tax practice serving both regular clients of the firm and clients who consult us on specific complex tax matters. The tax practice includes advice with respect to mergers and acquisitions; liquidation of partnerships and corporations; partnership transactions; restructuring of solvent and insolvent companies; and real estate transactions, including "like-kind" exchanges. The tax practice also includes advice with respect to executive compensation arrangements and employee benefit plans, such as employment agreements, stock options, non-competition agreements, incentive compensation plans, and employee stock ownership plans (ESOPs). We represent clients in disputes with the Internal Revenue Service and the New York State Department of Taxation, including litigation in the U.S. Claims Court and the Tax Court. A portion of our tax work relates to international tax planning, with regard both to foreign individuals and companies who engage in transactions in the U.S., and U.S. companies and individuals who engage in transactions offshore.

The firm has state-of-the art software programs and systems to assist in tax planning and tax compliance for a variety of individuals and entities. In the Trusts and Estates area, the firm commonly prepares estate tax and fiduciary income tax returns for the estates and trusts it represents.

Recently, there has been significant activity in the mergers and acquisition area, and the firm has structured several tax-free merger transactions. Another recently active area has involved "like-kind" tax-free exchanges of real estate.

The tax practitioners also work in other Practice Areas, such as Trusts and Estates, Charitable Gift Planning and Exempt Organizations with respect to sophisticated estate planning matters and succession planning for closely held businesses.

A sampling of our firm’s work in Taxation includes the following:

Structure of $8 million reverse triangular merger as a tax-free reorganization under Sections 368(a)(1)(A) and 368(a)(2)(D) of the US Internal Revenue Code;

Section 1031 tax-free like kind real estate exchange structuring;

Life-Nonlife Tax Consolidations for multinational variable insurance product company clients;

Global tax planning for transnational foreign company and individual investment in the U.S.

For further information on our Taxation practice area, please contact Howell Bramson.