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SF Oakland Bay Bridge

We help align your business with your legal and tax structure to achieve the optimal tax result. This includes: (i) tax planning advice for businesses, (ii) tax structuring and documentation for business transactions, and (iii) international tax.

Tax Planning

Our tax planning services include:

  • structuring equity compensation to minimize tax liability,
  • maximizing the tax benefit of business losses,
  • structuring business for token sales and initial coin offerings (ICOs), and
  • structuring companies to maximize the tax benefit from the new pass-through tax deduction under Section 199A.

We can help businesses that want to lower their taxes in response to tax reform; to maximize the tax benefits of exit payments to retiring partners or LLC members; or want to structure an expansion, a sale of a business division or any other change to a business.

Transactions

Tax planning for transactions includes mitigating tax risk for buyers and sellers in M&A transactions, structuring tax-efficient sales and acquisitions of companies (including LLCs, S-Corporations, C-Corporations and foreign corporations), and the tax aspects of joint venture agreements. Representative transactions include:

  • Advised a variety of companies on the domestic and international tax aspects of initial coin offerings (ICOs).
  • Represented private equity fund on tax issues in its acquisition of a late stage startup software company serving the hospitality industry.
  • Advised software and technology company in building materials industry on tax aspects of the acquisition of strategic technology target.
  • Represented U.S. controlling shareholder of Swiss pharmaceutical company treated as “Controlled Foreign Corporation” on complex partial sale and partial merger transaction with UK pharmaceutical company.
  • Counseled private equity fund on tax aspects of its acquisition of an international technology and accounting services group for the hedge fund industry.

International

We routinely advise businesses on a variety of international tax issues, including:

  • the sale and acquisition of foreign corporations by U.S. businesses;
  • inbound investments by foreign corporations making portfolio investments or strategic acquisitions in the United States; and
  • the tax aspects of outbound cross-border and international transactions by U.S. taxpayers.
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