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Our tax attorneys provide companies and partnerships with a broad and integrated approach to tax advice.  Our attorneys advise on individual transactions, assist with tax planning and compliance.  Our tax team assists in resolving disputed tax issues with taxing authorities and in Court in conjunction with our Trial and Class Action team.  We provide current, creative and integrated advice to create practical, effective and efficient solutions to complex tax issues. 

In addition to our tax attorneys, attorneys in related practices often work with our tax team to counsel clients on corporate issues, insurance, securities, restructurings, compliance and litigation.  Our attorneys advise on tax considerations in the formation and viability of contemplated transactions, which often involve multinational businesses and raise complex tax issues.  Our experience includes:

Foreign and Domestic Property/Casualty Tax Work

  • Provided analysis on myriad projects regarding the controlled foreign corporation rules, trade and business issues and related tax treaty issues, federal excise tax (FET) issues, and U.S. withholding tax and other issues.
  • Advise on branch tax issues, and section 842(b) issues.
  • Advise on issues regarding insurance accounting, including tax accounting for reserves.
  • Advise on reserve issues regarding valuation allowances.

Mergers and Acquisitions

  • Counseled on the formation of a multi-million dollar capitalization mutual municipal bond insurer.
  • Provide analysis of tax issues associated with the purchase/merger/reinsurance.

State and Local Taxes

  • Knowledge of the structure and operation of state premiums taxes and retaliatory  taxes, surplus line taxes and direct placement taxes, and associated constitutional law issues.  
  • Advise clients on the state and local tax implications of corporate transactions and reorganizations. 

Federal Tax

  • Provide strategic advice on tax implications in a broad range of transactions including mergers and acquisitions, real estate transactions, restructurings, partnerships and derivatives. 

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