Taxation

The advice of a seasoned tax attorney is invaluable when forming a business, buying or selling a business, entering into intercompany agreements, or resolving disputes. The tax ramifications of these activities require careful analysis and consideration of individual needs. The expertise of our taxation attorneys is constantly sought by our other practice professionals and clients in these three important areas.

Business Taxation. We help clients who are forming and running businesses to examine the tax ramifications of:

• Entity selection: partnership, limited liability company and joint venture formations and transactions, including the formation of operating entities and investment funds
• Tax and accounting consequences of executive compensation plans, including restricted stock, qualified and nonqualified options, equity hybrids and matters relating to golden parachute payments.
• State taxation of multistate business operations, including Massachusetts corporate excise and sales and use taxation.

Transactional Taxation. We also assist businesses in structuring the the following transactions to be most tax favorable:

• Acquisitions and dispositions of businesses and business interests, including stock and asset purchases and sales, management and leveraged buyouts, and taxable and tax-free mergers and acquisitions
• Venture capital and other equity financings and investments
• Debt financings, refinancings and restructurings
• Recapitalizations, redemptions, spin-offs, split-offs and split-ups
• International transactions and business operations, including in-bound investments by foreign nationals and businesses and out-bound investments by United States nationals and businesses

Tax Controversy. Our attorneys represent clients before all federal, state and local taxing authorities in connection with audits and tax collections, including payment agreements, settlements, seizures, liens, and tax appeals before various administrative tribunals, and state and federal courts at all levels. In particular, we represent clients in contesting state income tax liability resulting from their business activities, and in contesting and settling proposed sales and use tax liability. Our attorneys also have extensive experience representing clients in complex disputes before the Internal Revenue Service Appeals Division and in all phases of litigation before the United States Tax Court.

To discuss your specific taxation issues, and how our experienced attorneys might serve you more efficiently and responsively, please contact Bob Finkel or Chip Wry.