Tax Planning and Controversy

All transactions have tax consequences, which can significantly affect financial performance.  So oftentimes it is not enough to execute a transaction in the simplest way possible.  As lawyers, we must understand a client’s goals and figure out how to execute in the most tax efficient manner while not permitting the tax effect to drive the business result.  This is an area of our practice where we provide enormous value to our corporate clients — planning transactions to take maximum effect of the tax laws given the client’s tax posture at the time of the transaction and the client’s expected tax posture at the time of the tax consequence.