A practice dedicated to tax, but not limited to tax.

Practice focuses on tax controversies. Relevant areas include income, employment and sales tax audits, collections, and voluntary disclosures, including disclosures of offshore accounts and Foreign Bank Account Reports (FBARs).

Tax Associate – general tax practice involving the structuring of mergers and acquisitions, investment partnerships, and operating companies, advising on state and local tax matters, planning gifts and estates, and contesting tax deficiencies. Relevant matters have included:• Structuring the U.S. sales subsidiary of a foreign software producer to minimize state and local tax liabilities and avoid having payments from subsidiary to parent treated as U.S.-source royalties.• Structuring the merger of a federal savings bank into a state mutual savings bank to obtain asset purchase treatment for the acquiring savings bank.• Structuring film production financing for a foreign copyright owner to preserve certain foreign tax benefits and avoid adverse U.S. tax consequences.• Analyzing state and local tax issues affecting the global operations of a foreign investment fund, including nexus and unitary business issues.• Reviewing and drafting offering memoranda and related documents for investment funds.

Tax Associate – general tax practice involving all aspects of federal, state, and international tax law. Relevant matters included:• Reviewing and drafting offering memoranda and related documents for investment funds.• Structuring the global business activities of a music entertainment enterprise to minimize the U.S. income tax consequences to the nonresident alien individuals carrying on that enterprise.• Analyzing and quantitatively modeling complex allocation and distribution provisions in the course of restructuring investment management partnerships.• Contesting federal and New York State income tax audits at the administrative level.• Advising high net-worth individuals on U.S. trust, estate, and gift tax matters.

Bank Regulatory Associate – practice focused on the non-banking activities of U.S. and foreign bank holding companies and non-bank financial companies. Relevant matters included:• Researching, analyzing, and advising on federal and state banking laws and regulations.• Drafting and negotiating regulatory submissions to the Federal Reserve, including Financial Holding Company applications and requests for permission to engage in various activities.