Corporate Acquisitions and Dispositions
Representing both domestic and foreign acquirers and targets in taxable and nontaxable stock and asset acquisitions and dispositions. Our tax advice is closely integrated with our clients’ business planning in order to increase the tax effectiveness of their transactions. Therefore, our analysis of direct tax consequences of a transaction at hand is customarily accompanied by advice concerning the broader tax planning implications—including identification of potential risks and potential opportunities.

International Taxation
Our lawyers have extensive experience and capabilities with respect to the U.S. income tax consequences to U.S. and non-U.S. persons in connection with their U.S. and foreign investments and operations.

• Outbound Tax Planning. With respect to U.S. persons, we have served as primary tax counsel to many in connection with structuring their foreign operations, and advice concerning ongoing taxation issues. In particular, we regularly provide advice to our clients concerning structuring their foreign operations to avoid controlled foreign corporation and passive foreign investment company status; Subpart F issues; contract manufacturing; transfer pricing; issues related to various financings and credit facilities; achieving maximum utilization of U.S. foreign tax credits; foreign acquisitions and foreign branch losses and recapture thereof.
   
• Inbound Tax Planning. We have served as primary tax counsel to non-U.S. persons with respect to investments and operations within the U.S. In this capacity, we regularly advise our clients concerning their U.S. income tax exposure, minimizing the risk of being considered to be engaged in a U.S. trade or business; branch profits tax issues; withholding tax issues; conduit financing issues, earnings stripping and tax treaty implications.

Structured Tax Advantaged Products
Working closely with investment banking clients and other financial institutions, we structure and analyze techniques to achieve favorable tax results, including "double dip" financings, increased foreign tax credit utilization, deferral of taxable gains, triggering and increasing taxable losses, and the repatriation of foreign earnings with no net additional U.S. tax.

Partnerships (LLCs) and Other Investment Vehicles
Tax advice with respect to structuring operations and investments through the use of partnerships, LLCs and other investment vehicles, and the use of partnerships and LLCs with respect to various tax-advantaged disposition strategies.

State and Local Taxation
Our tax group has notable experience and capabilities with respect to state and local tax planning and tax reduction strategies as well as sales and use tax planning to multistate corporations.  Review our summary of State and Local Tax Services.

Real Estate Transactions
Our tax group has extensive experience in planning for a broad range of partnership and real estate transactions, including corporate joint ventures, start-up ventures, real estate ventures and real estate development. We have also provided advice in connection with the formation and operation of securitization vehicles, such as real estate mortgage investment conduits ("REMICs") and grantor trusts, as well as advice with respect to real estate investment trusts ("REITs"). Further, members of the tax group, as part of the affordable housing group at Sonnenschein, are among the leading experts in low-income housing tax credit and new markets tax credit issues.

Financial Instruments
Advice in connection with various debt and equity offerings including structures involving the issuance of debt through grantor trusts and trust preferred securities. Structuring derivative financial products to achieve tax arbitrage in different taxing jurisdictions and advising on the tax implications of issuances of domestic and foreign debt and equity in U.S. markets. Advising clients on the holding, modification and disposition of troubled debt instruments.

Workouts/Bankruptcy
Advising clients - whether requesting debtors’ or creditors’ committees - regarding structuring corporate and partnership bankruptcies and workouts to preserve net operating losses and avoid income recognition on the restructuring of the debt and equity of the entities involved.

E-Commerce
Advising clients engaging in e-commerce regarding corporate structures that will reduce their U.S. federal and state income taxes and state sales taxes, in addition to advising investors in such businesses concerning various tax advantaged strategies, including the "rollover" of qualified small business stock.