Tax Planning + Tax Litigation
Tax Planning
The lawyers of Hobson Bernardino + Davis LLP routinely provide international and domestic tax planning services to individuals, partnerships, limited liability companies and corporations. We take the lead in structuring business entities and transactions in a tax-efficient manner, cognizant that structural and transactional tax costs in a business deal need to be addressed early and effectively to preserve the economics of the deal and expectations of the parties involved. In tight credit markets and rising tax rates environment, our tax lawyers assist businesses in identifying optimal tax structures for acquiring and disposing of business assets and liabilities, consolidation and divestiture of profitable or loss business units and entities and retaining executives and top talent.
Many of our clients are closely-held and middle market businesses that engage in entertainment, technology, biotechnology, media, retail and health care sectors through corporate or passthrough entity structures such as limited liability companies, S corporations and partnerships. Our clients look to our firm for reliable advice on tax issues relating to business formations, transactions, executive compensation, and exit strategies in joint venture arrangements. We have significant experience in the following areas:
- Domestic and cross-border taxable and tax-free mergers and acquisitions, reorganizations, spinoffs and joint ventures.
- Debt and equity financing, third party and intercompany loans.
- Specialized investment and financing vehicles such as hedge funds, investment partnerships and real estate investment trusts (REITs).
- Structuring complex like-kind exchanges including reverse exchanges, exchanges of large portfolios of real estate, exchanges of intangible assets and aircraft assets.
- Structuring of film financing, production and distribution deals involving federal Section 181 deductions and state film tax credits and incentives.
- Federal low-income housing and renewable energy tax credit issues with one of the nation’s leading practices, including representation of equity investors, developers, syndicators, housing authorities, and lenders throughout the United States.
- Representation of equity investors and developers in transactions structured to qualify for the historic rehabilitation tax credit and/or the new markets tax credit.
- Representation of tax-exempt organizations in the full range of issues they face including formation and restructuring, obtaining and maintaining tax-exempt status, assistance in audits and internal investigations.
State + Local Tax Planning
We have substantial experience advising clients in connection with state and local income, sales, use, franchise, and other taxes, and structuring business transactions to manage such taxes. Our counsel has proven invaluable to established manufacturing and retail businesses and new technology businesses alike.
Tax Controversies + Litigation
We represent clients in all aspects of controversies with the Internal Revenue Service and with state and local tax authorities. We handle audits, coordinated exams, administrative appeals, and cases in federal and state courts. We have specialized experience in international taxpayer audits.