Tax

Overview

Tannenbaum Helpern's tax lawyers work closely with the firm's various practice groups to structure transactions to achieve the most favorable tax results, by understanding the relevant tax issues and economic factors to provide creative solutions to help clients achieve their business, financial and personal goals. In addition to domestic clients, Tannenbaum Helpern's Tax Law practice advises U.S. companies and individuals doing business abroad and foreign individuals and corporations doing business in the U.S. in a practical, business and goal-oriented manner. Tannenbaum Helpern's tax attorneys have deep knowledge in the tax aspects of domestic and offshore investment vehicles, cross-border transactions, real estate matters, partnership taxation and business restructurings.

Knowledge

Tannenbaum Helpern's tax lawyers provide concentrated legal services with regard to the following areas:

Investment Funds

We represent private funds and their sponsors in connection with fund formations, portfolio investments and disposition transactions. Tannenbaum Helpern's tax lawyers work with clients in private equity, real estate and hedge funds, and they advise clients on tax planning for hybrid and other fund structures. Tannenbaum Helpern's Tax Law practice has considerable experience advising investors on their investments in funds, structuring seed investments and optimizing tax results for sponsors. Investor clients include family offices, tax-exempt investors, non-U.S. investors and sovereign wealth funds.

International Tax Planning

Tannenbaum Helpern tax attorneys advise clients internationally on U.S. tax aspects of inbound investments, the U.S. tax aspects of U.S. activities of non-U.S. businesses, global restructurings and minimizing of worldwide effect tax rates.

Real Estate Transactions

Tannenbaum Helpern's tax lawyers represent real estate investors, fund managers and developers. Increasingly, real estate transactions involve sophisticated partnership agreements and complex equity participations, convertible or participating obligations and debt restructurings, and Tannenbaum Helpern's Tax Law practice actively participates in structuring and drafting these arrangements. We also regularly advise on the structuring of cross-border real estate investments.

Business Combinations and Divestitures

Tannenbaum Helpern's tax lawyers regularly represent clients on the tax aspects of mergers, acquisitions, dispositions, joint ventures, restructurings and other business combination and divestiture transactions. Tannenbaum Helpern's Tax Law practice works closely with the firm's Corporate practice early in the transaction process to select the most effective structures from both foreign and U.S. tax perspectives, taking into account business and non-tax legal issues. This work regularly involves a wide range of domestic and cross-border tax structuring and related planning projects.

Individual Tax Planning

Tannenbaum Helpern's Tax Law practice advises individuals on a wide variety of personal and business planning subjects, including matters concerning employee compensation, personal investments, U.S. tax residency, closely held businesses, charitable donations and the formation, operation and investments of tax-exempt organizations. In addition, Tannenbaum Helpern's tax lawyers work with the firm's Trusts and Estates practice to advise individuals on matters concerning income tax planning in conjunction with estate and gift tax planning.

Representative Services

• All aspects of Federal, State and City personal and business tax issues for U.S.-based and foreign taxpayers
• Formation, operation and liquidation of partnerships and limited liability companies and disposition of interests in partnerships and limited liability companies
• Structuring of U.S. and international funds and other pooled investment vehicles and the sponsors of such vehicles and providing on-going tax advice in connection with the operations and investments of such funds and sponsors
• International tax issues re: controlled foreign corporations, passive foreign investment companies, FIRPTA, FATCA, tax treaties, cross-border mergers and acquisitions, cross-border joint ventures
• The U.S. business and investment activities of foreign persons and business enterprises
• The foreign business and investment activities of U.S. persons and business enterprises
• Corporate tax matters, including mergers, acquisitions and dispositions of corporations
• Executive compensation, deferred compensation arrangements, incentive and nonstatutory stock option plans, profits interest plans and phantom stock or interest plans
• Real estate and venture capital syndications, tax-free exchanges of like-kind property, acquisitions and dispositions of real property
• Opinion letters and ruling requests to the Internal Revenue Service
• The operations and investments of tax-exempt organizations