Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business, from the formation through operations to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities.

Business Structuring

Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business, from the formation through operations to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities. Our areas of representation for clients in taxation matters include:

  • Choice of Entity Analysis
  • Partnership Tax Planning
  • LLC Tax Planning
  • C Corporation Tax Planning
  • S Corporation Tax Planning
  • Disregarded Entity Planning
  • Partnership and LLC Agreements (including Special Allocations)
  • Buy-Sell Agreements
  • Entity Formations, Joint Ventures and Liquidations
  • Financing and Recapitalizations
  • Texas Franchise / Margin Tax Planning

Entity Combinations, Divisions, and Restructuring

Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business, from the formation through operations and then to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities. Our areas of representation for clients in taxation matters include:

  • Tax-Free Acquisitive Reorganizations
  • Tax-Free Divisive Reorganizations
  • Tax-Free Spin-Offs, Split-Offs and Split-Ups
  • Partnership Divisions (Assets-Up and Assets-Over)
  • Structured Taxable Acquisitions and Divestitures (including §338 Transactions)
  • Allocation of Sale Proceeds
  • Personal Goodwill Dispositions
  • Installment Sales
  • Related Party Transactions
  • Net Operating Loss Limitations

Oil and Gas Taxation

Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business,from the formation through operations to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities. Our areas of representation for clients in taxation matters include:

  • Intangible Drilling Costs
  • Depletion
  • Entity Formation and Planning
  • Acquisitions and Divestitures
  • Tax Treatment of Mineral Interests
  • Structuring Partnership and Joint Venture Agreements

Deferred Compensation Structuring

Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business, from the formation through operations to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities. Our areas of representation for clients in taxation matters include:

  • Incentive Stock Option (ISO) Plans
  • Non-Qualified Stock Option (NSO) Plans
  • Carried Interest Structures
  • Restricted Stock Plans
  • Stock Appreciation Rights (SAR) and Phantom Equity Plans
  • Section 409A Compliance
  • Cash Bonus Plans
  • Welfare Benefit Plans
  • Distribution Planning in Connection with Deferred Income Vehicles

Individual Taxation

Our firm’s tax attorneys provide innovative advice on, and planning solutions to, the various federal and state tax issues encountered by our clients. Our tax attorneys work closely with other attorneys in the firm to formulate an overall planning strategy that addresses all of the issues confronted by the client while minimizing the tax costs and maximizing the tax benefits. Our tax attorneys are experienced in federal and state tax planning for all phases in the life cycle of a business, from the formation through operations to the exit strategy. We represent closely held corporations, partnerships, limited liability companies and individuals on the federal and state tax consequences of various business structures and advise on the most efficient tax structure in conducting their business activities. Our areas of representation for clients in taxation matters include:

  • At-Risk and Passive Loss Limitation Structuring
  • Installment Sales
  • Cancellation of Indebtedness Income
  • Related Party Transactions
  • Amortization and Depreciation Structuring
  • Compensation Planning
  • Capital Gain Planning
  • Dividend Planning

Estate Tax Planning

Our attorneys provide counsel during all phases of the estate planning process. Initial phase planning includes preparation of wills, family trusts, durable powers of attorney, medical powers of attorney and living wills.

Additionally, the attorneys in our estate planning department utilize various alternatives to accomplish our clients’ family wealth migration, family asset protection and family gift and charitable gift planning goals, including:

  • Family wealth migration generation-skipping trusts
  • Revocable and irrevocable trusts
  • Life insurance trusts
  • Grantor trusts
  • Grantor retained interest trusts, including personal residence, grantor retained annuity and unitrusts
  • Sophisticated beneficiary designation planning for IRAs, qualified plan and other benefits
  • Charitable planning charitable remainder trusts
  • Charitable lead trusts
  • Charitable gift annuities
  • Private family foundations

The section also provides continued legal and tax representation to charitable organizations, both public charities and private foundations. Further, attorneys in the Probate, Trust and Estate Administration section provide representation and assistance in the administration of the estate or trust, including probate administration and postmortem tax planning

Generation-Skipping Transfer Tax Planning

We provide a broad range of services in gift, estate and generation-skipping transfer tax. Any time a client wishes to transfer assets to another member of the client’s family, transfer tax implications should be considered. Each lawyer works with the individual client to structure the transfer of assets in the most tax efficient manner, maximizing the use of all available credits, exemptions and exclusions that are available under the gift, estate and generation-skipping transfer tax laws.

Gift Tax Planning

Income Tax Planning for Estates and Trusts

Our firm’s attorneys provide representation to fiduciaries and other clients related to the income tax implications and characteristics of trusts and estates. The income tax implications are related to transactions with trusts and estates as well as structuring assets of trusts or estates for the most favorable treatment from an income tax perspective. It includes practical planning and procedural advice on sale, transfer and distribution transactions, tax basis determinations, and income tax planning on IRAs, retirement plans and items of income in respect of a decedent.

Exempt Organizations

Our firm represents tax-exempt organizations on a broad spectrum of issues. The firm has significant experience representing tax-exempt entities, including public charities, private foundations, social welfare organizations, professional associations, social clubs, homeowners’ associations and other 501(c) organizations. The firm also has particular expertise in representation of religious organizations. Our attorneys are experienced in exempt organization issues and speak regularly on topics related to tax-exempt organizations. The firm provides a multidisciplinary approach to representing tax-exempt entities by involving attorneys throughout the firm to advise on specific areas (such as real estate law or commercial litigation) in conjunction with attorneys having knowledge of the uniqueness of the tax-exempt sector. In addition, the firm offers services specific to tax-exempt entities including, but not limited to, the following:

  • Formation and Tax-Exempt Status
  • Governance and Fiduciary Duties
  • Best Practices and Written Policies
  • Intellectual Property
  • Grant making (including exercising expenditure responsibility)
  • Annual Information Returns
  • Unrelated Business Income Tax Issues
  • Registration for Charitable Solicitation
  • Fundraising Issues
  • Planned Giving and Donor Relations
  • Community Foundations (including Donor-Advised Funds and Endowed Funds)
  • International Charitable Transactions
  • Attorney General Investigations