Excellence in Action
Client Service Examples
Tax Reform
Developing strategies and actively restructuring clients’ organizations, their contracts and their leases, to receive the benefits available under new and developing legislation.
Partnership Audits
Trained regional Certified Public Accounting Firms, including CPAs in multiple offices, on compliance and strategy pertaining to the Partnership Audit Tax Regulations.
Midco & Tax Controversies
- Defended a referred client in a Midco tax shelter over a period of more than 10 years, resulting in no tax liability.
- Active tax controversy practice. Reduced or abated $3 million of liability in one year, multiple clients.
- Multiple state tax appeals pending, CAT tax for client in education and sales/use tax for clients in the mining industry.
Transactional & Restructuring
- Lead counsel on nine-figure M&A transaction, part equity part tax deferred sale to joint venture of two private equity companies; structured deal and tax aspects, closed mid-April.
- Restructured the sale of a significant private closely held corporation adding $600 million in value.
- Restructured as taxable the stalled acquisition of a two domestic corporations by a widely held foreign client intended as tax deferred (inversion), adding value for all parties.
- Restructured a natural gas pipeline easement grant to be tax free, for cash, without reinvestment of the proceeds as an involuntary conversion or like kind exchange. Six-figure amount. Renegotiated the business transaction for client, increased closing sale price.
- Restructured the sale of a line of business to a publicly traded company as the sale of a patent portfolio, a nine figure deal, and a ten figure transaction for a privately held company being acquired by a publicly traded company, adding value for all parties.
Additional Experience
- Diligenced and remediated family owned and service firms for acquisition by publicly traded companies.
- Coordinates amnesty and voluntary disclosure for domestic taxpayers, expats and estates under the Offshore Voluntary Disclosure Program, Streamlined Program, and Silent Disclosure; defended a referred US Person in an FBAR examination resulting in “no-change.”
- Testified before US Treasury on the scope of IRC section 337(d) regulations on behalf of a nonprofit social club.