Tax Planning

We are, first and foremost, tax attorneys. We have spent countless years engaging in hundreds of transactions trying to outwit the tax man. Today, our practice focuses on the more sophisticated and difficult aspects of tax planning.

Gain Deferral

We commonly work with real estate investors and business owners looking to sell their appreciated assets and facing a large tax on sale. We assist them with strategies designed to defer the recognition of capital gain. Usually, our clients can cash out on the sale of an appreciated asset today, but pay the tax many years from now.

This type of planning requires great care and will not work on a last minute basis. We would be happy to discuss these strategies with you in more detail to determine if they would be appropriate in your tax planning.

Obtaining Deductions

Many taxpayers look for ways to reduce their taxable income in a legal and workable manner. Our strategies allow you to take large deductions, ranging from $100,000 to $5,000,000, without losing control of your money or subjecting you to IRS scrutiny or penalties.

For example, we recently assisted a doctor with $3,000,000 in annual revenues in obtaining a $300,000 deduction. Unlike a contribution to a retirement plan, our structure allowed the doctor to retain complete control over the cash, and resulted in no loss of liquidity.

Many manufacturers, contractors, doctors and other high income taxpayers commonly avail themselves of these deductions. To find out if one of these strategies may be appropriate for you, please call us.

Converting Ordinary Income to Capital Gain

Real estate developers are usually subject to ordinary income on the sale of real estate. With proper planning, we allow our clients to convert what would otherwise be ordinary income into a capital gain. In some cases we may even afford them the benefit of deferring the recognition of the capital gain on sale. As with any other tax planning strategy, converting ordinary income to a capital gain requires careful planning and structuring, in advance of the sale.

Structuring Offshore Operations

We assist many clients, whether startup or established companies, with all of their operations and business activities outside of the United States. Typically, this involves developing tax-efficient investment structures, transfers of intangible property, availability of foreign tax credits, ensuring deferral of taxable income recognition and minimizing withholding taxes.

Over the years we have represented numerous internet-based companies, including online gambling, adult entertainment, entertainment content distribution and others. In many instances, we have succeeded in structuring our client’s operations to avoid or defer most US-based taxes.