The right team to resolve controversies and protect the client’s interest.
Our Tax practice group is recognized for its innovative tax planning and structuring advice and its success in representing clients before the Federal, New York State and New York City taxing authorities.
Tax Planning and Structuring:
Our tax attorneys advise businesses on a variety of tax matters, including tax considerations associated with a range of financial transactions including mergers and acquisitions, structuring business entities, choice of business entity, separation of ownership, and the acquisition, disposition and like-kind exchange of real estate and other assets. The Tax practice group works with all kinds of entities, including C corporations, S corporations, Partnerships, Limited Liability Companies and Partnerships, and Trusts, and regularly teams up with the transactional attorneys in our Corporate and Securities practice group to provide innovative approaches to structuring practical and effective solutions to the challenges facing business owners and entrepreneurs.
Our Tax practice group routinely assists our Not-for-Profit group by assisting tax exempt organizations with formation options, governance options, the creation of organizational documents and applications for recognition of tax-exempt status by the Internal Revenue Service.
We have also successfully represented clients before the Pension Benefit Guaranty Corporation and continue to assist qualified pension plans with issues involving prohibited transactions, minimum funding deficiencies and other matters related to their qualified status.
Tax Controversies and Litigation:
Our tax controversy and litigation attorneys, which include a former Senior Attorney with the Internal Revenue Service Office of Chief Counsel and the IRS Estate and Gift Tax Division, have over forty years of combined experience representing individuals and businesses in all stages of Federal, State and City tax disputes, including Examinations, Appeals, United States Tax Court litigation, Federal Court of Claims, New York State Conciliation Conferences and the New York State Division of Tax Appeals. We also represent clients before the Collection Divisions of each taxing authority in matters involving Levies, Liens, Warrants, Property Seizures, and Driver’s License suspensions due to unpaid New York State tax liabilities. We have also secured rulings from the Internal Revenue Service on a variety of tax matters on behalf of clients.
Our tax controversy and litigation attorneys are skilled negotiators and have handled Offers in Compromise, Installment Payment Agreements, Collection Due Process Appeals, Innocent Spouse Claims, Responsible Person Assessments, Sales Tax and Nexus Matters, and New York State Residency audits and nonresident income allocation audits.
We assist clients with issues of non-compliance, including penalty assessments, failures to file accurate returns, non-filer matters, and voluntary disclosures. Our tax controversy and litigation attorneys have negotiated countless domestic and offshore voluntary disclosures with both the Internal Revenue Service and New York State Department of Taxation and Finance. Through these efforts, we have limited clients’ exposure to various civil and criminal penalties, helped clients become current with their U.S. tax obligations, and, in matters involving foreign bank accounts and the non-reporting of foreign source income, have helped clients avoid criminal prosecution.