Our Federal Tax practice group lawyers have extensive experience in the tax aspects of mergers, asset and stock sales and acquisitions, tender offers, restructurings in and out of bankruptcy, recapitalizations, divestitures, spin-offs, leveraged buyouts in the domestic and cross-border context involving multinational corporations, partnerships, S corporations, and other legal entities.
We successfully assist our worldwide clients with all aspects of U.S. federal income tax planning and strategy. We provide skilled advice to businesses in every industry, working alongside you and your team to ensure compliance while leveraging tax opportunities to meet your business objectives.
Our Services
We provide strategic planning advice and represent our clients in connection with a vast array of matters, including:
- Buyouts of assets and distressed companies in the bankruptcy context, and unique tax planning concerns involving S corporations and closely held businesses
- Capital market and derivative investments, including debt financing, structured finance, securities lending, and repos
- Debt-equity swaps, recapitalizations, and distressed loan transactions
- Inbound and outbound investment and expansion, international joint ventures, and work with tax treaties and withholding rules
- Merger and acquisition transactions, including opinions regarding reorganizations and spin-off transactions and advice regarding post-transaction separation of functions and tax sharing agreements
- Partnership tax issues (including for 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
- Private equity transactions, including leveraged and management buy-outs
- 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
- Structuring of nonregulated investment vehicles for tax-sensitive investors, such as tax exempt organizations and foreign persons
We are also proficient with public mergers and the related Securities and Exchange Commission (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, considering tax and nontax concerns.
Our Team
With a national reach, our Federal Tax team uses a cross-disciplinary approach to create legal solutions tailored to the unique characteristics of client, collaborating with colleagues across our firm’s practice groups, including capital markets, real estate, bankruptcy, finance, intellectual property, international, and mergers and acquisitions.
Our firm’s Tax practice group has been recognized as a Tier One law firm in Tax Law in Hartford, Connecticut by U.S. News and World Report Best Law Firms since 2010. Our practice group has also earned rankings in Tax Litigation in Hartford since 2011.
Wherever your business operates in the marketplace, our top-tier Federal Tax practice group provides strategic advice and service across all industries. We are equipped to help you solve your most pressing tax issues to meet your objectives.
Experience
Federal Tax Representation
- Represented a Singapore-based software developer in connection with U.S. federal income tax matters involving U.S.-based internet and distribution activities.
- Represented a Canadian paper products company in connection with acquisition of operating assets in the United States, involving attention to the Canada U.S. income tax treaty.
- Represented a multi-industry company, whose principal activities are to design and manufacture nickel-zinc rechargeable batteries, in connection with its acquisitions of Sontek Industries Inc. in a tax-free merger involving management of net operating losses and Internal Revenue Code section 382 considerations.
- Represented a large privately held electrical supply distribution business in its sale to a private equity-sponsored buyer. The representation involved resolution of "applicable high-yield debt obligation" concerns with respect to debt financing.
- Represented a Boston-based private equity firm in all of its merger and acquisitions activity and post-acquisition restructurings of its portfolio companies.
