Federal Tax Representation
Members of our Tax Group have substantial experience in assisting clients in connection with a variety of complicated federal tax matters, including advice and planning with respect to business transactions, investment and financing structures, capital market transactions and business arrangements that transcend state and national boundaries.Our tax lawyers have extensive experience successfully assisting our clients in connection with mergers, asset and stock sales and acquisitions, tender offers, recapitalizations, divestitures, spin-offs, and leveraged buyouts involving multinational corporations, partnerships, S corporations and other legal entities. As illustrated in our representative matters, Robinson & Cole has participated in many of the most sophisticated recent mergers and acquisitions transactions in the Northeast. We frequently represent mid-size and large privately-held companies in their most significant transaction – the sale of their business. Our experience also includes public mergers and the related SEC disclosure issues, public-private transactions and private transactions involving a variety of complicated U.S. federal, state, local and foreign tax considerations. Our tax lawyers get involved at the inception of the transaction to ensure that it is structured in the most tax efficient manner for all parties involved, taking into account tax and non-tax concerns.
Our tax lawyers regularly represent client with respect to partnership tax matters (including limited liability companies), such as structuring joint ventures (cross border and domestic); mergers and acquisitions and structuring compensatory arrangements involving partnerships and limited liability companies.
We often are asked to provide strategic planning advice and representation with respect to inbound and outbound investment and expansion, international joint ventures, and tax treaty planning.
In the capital markets area, our tax attorneys advise on public and private offerings of various types of debt and equity instruments, including convertible and exchangeable securities, stock and debt offerings with warrants or other securities, and preferred securities.
More specifically, we regularly assist clients with a wide range of complex tax matters including:
- Merger and acquisition transactions, opinions regarding reorganizations and spin-off transactions and advice regarding post-transaction separation of functions and tax sharing agreements
- Capital market and derivative investments, including debt financing, structured finance, securities lending and repos
- Buyouts of assets and distressed companies in the bankruptcy context, and unique tax planning concerns involving S corporations and closely held businesses
- Structuring of non-regulated investment vehicles for tax-sensitive investors, such as tax exempt organizations and foreign persons
- Assistance on both inbound and outbound investments, including international joint ventures and work with tax treaties and withholding rules
- Private equity transactions, including leveraged and management buy-outs
- Partnerships and other joint venture arrangements
- Debt-equity swaps, recapitalizations and distressed loan transactions
- Public and private real estate transactions
- Assistance in preserving net operating losses and other tax attributes in connection with acquisition, reorganization and ownership-shift transactions
- Analysis and opinions regarding uncertain tax positions, including FIN 48 compliance
For our recent experience in the U.S. federal tax arena, which includes rendering strategic planning advice and representation, please click on the experience link at the top of the page.
- IRS Issues Proposed Regulations with Respect to FATCA, published in Robinson & Cole Tax Legal Update, 2/17/2012
WHAT’S NEW
| 6.18.13 | Susan E. Roberts Elevated to Counsel at Robinson & Cole LLP |
| 6.11.13 | Susan Roberts Speaks at NBI Seminar |
