Domestic Tax Planning for Business Operations
Structuring of all forms of U.S. and Israeli business operations to achieve the most beneficial income tax treatment.
Tax Planning with Respect to Transfers of Business Interests
Structuring of mergers, acquisitions, sale and purchase of businesses and joint ventures to minimize income taxes imposed on transfer of assets and interests.
International Tax Planning for Individuals
U.S. income and transfer (estate and gift) tax planning for foreign persons who operate businesses within the U.S., transfer assets into or acquire property in the U.S. or who are becoming U.S. residents or citizens. Tax planning for U.S. persons operating businesses outside of the U.S., transferring assets out of the U.S. or who are terminating their status as U.S. residents or citizens.
International Tax Planning for Businesses
Structuring multi-national businesses to achieve maximum tax efficiency, with emphasis on functionality, efficiency and practical considerations. Advantage is taken of the benefits available under international tax treaties and, where applicable, use of companies located in low tax jurisdictions.
Tax Defense Work
Representation of clients before federal, state and local tax authorities with respect to audit issues. Conduct of negotiations with tax authorities to reach settlement of audit issues where possible.
Representation of clients before tax authorities with respect to collection issues, including negotiation of installment payouts, offers in compromise, innocent spouse relief, propriety of tax lien claims and priorities of tax liens. The Firm also has an expertise in issues related to the ability to discharge tax liabilities in bankruptcy.
Estate and Gift Tax
Representation of clients with respect to all aspects of estate and gift tax planning including use of the credit shelter trusts, life insurance trusts, annual gift tax exemption, qualified personal resident trusts, and qualified domestic trusts for non-citizens.