Our tax attorneys represent clients in all aspects of estate and gift taxation, corporate, partnership, trust, fiduciary and individual federal and state income taxation, as well as sales and use taxation, ERISA and executive compensation, and the taxation of nonprofit entities.
Because virtually all transactions have tax implications, our attorneys frequently collaborate with attorneys in other practice areas to evaluate, negotiate, and structure our clients’ transactions.
Business Tax Planning
The Tax practice group, working with the firm’s Business and Corporate Transactions group, advises clients, including companies and their owners, on the federal, international, state, and local tax implications of entity formation, mergers, acquisitions, sales, and other transactions. Our tax lawyers can apply sophisticated techniques to accomplish the sale and financing of businesses, and maintain management and ownership continuity for closely-held businesses. We have substantial experience in planning transactions and in implementing tax-efficient corporate strategies for large and small businesses across industries.
Our tax attorneys play an integral role in counseling the firm’s clients on a wide variety of ERISA, employee benefits, and executive compensation matters. Along with the firm’s Employment practice group, the Tax practice group advises clients on the full range of tax, securities and labor law issues affecting executive compensation and employee benefit plans. Our lawyers advise on structuring compensation and benefit arrangements that satisfy client objectives relating to transition and succession concerns, designing and negotiating employment agreements, financial statement reporting, making public disclosure and anticipating tax impacts on the company and the executive.
The transfer of wealth between generations involves complex federal tax laws including the federal estate tax, gift tax, and generation-skipping transfer taxes. The firm’s Tax practice group collaborates with the Estates and Trusts group to coordinate our clients’ comprehensive estate plans with strategies to reduce federal estate taxes. Our lawyers and staff have become exceptionally well-versed in myriad facets of the estate tax, from assisting executors in complying with complex federal tax laws when administering estates to advising on special estate tax matters relating to closely-held businesses.
The Tax practice group’s skill set also includes representation of clients before the Internal Revenue Service and various California state tax administrative departments and agencies. We are involved in all areas of dispute resolution within the Internal Revenue Service regarding representation of fiduciaries in tax controversy matters concerning estate and gift tax audits, as well as return positions and refund claims involving negotiation and settlement at the audit level, and conferences at the appeals level for individuals and entities.