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Clients engaging in complex commercial transactions require creative and sophisticated tax advice to meet their immediate goals and to be in a position to easily adjust to changing laws and new opportunities.

  • Designed integrated global structures by creating tax-advantaged holding companies and intellectual property holding companies. Our legal services required evaluation of the tax-efficient capitalization plans for each business and plans for substantial Subpart F expansions into Europe by one of the largest U.S. privately-held companies and a significant Internet-based company.
  • Represented the family owners of a top retail products company in connection with the sale of their company to a public company, structuring the sale so as to give the client cash along with stock and diversify their portfolio with a significant holding of public company stock.
  • Obtained IRS rulings on a multitude of domestic and international corporate, financial product, and tax accounting issues in connection with public and private transactions.
  • Structured or restructured numerous multi-national groups in connection with acquisition and disposition transactions.
  • Obtained two favorable rulings from the IRS National Office on the current deductibility of renewable energy credits.
  • Negotiated joint ventures and limited liability company agreements with developers, pension funds, and venture capital funds.
  • Secured a research tax credit in the amount of $25 million on behalf of a regulated public utility.

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