Tax

• Tax and Tax Planning Matters

  • Represented a client in the planning and implementation of split-dollar life insurance arrangements
  • Represented a client in the services industry and, based on the judgment obtained by our Litigation Department, achieved a refund award in excess of $1 million for Federal employment taxes. Designed a tax structure that minimized Indian taxes on future gains and avoided application of the U.S. passive foreign investment company rules for a joint venture that acquired a controlling interest in a development stage Indian hotel company
  • Obtained $400,000 New Jersey sales tax refund for a new client who had failed to claim entitlement to the State’s “welcome stranger” exemption when purchasing an aircraft
  • Designed a tax structure that enable an offshore client and onshore clients to purchase a large portfolio of distressed residential mortgages on a tax-favored basis
  • Represented two family groups who wished to monetize their interests in a $100 million portfolio of New York City real estate held through a series of recently converted S corporations that they controlled
  • Designed and implemented a series of steps whereby a manufacturing enterprise conduct­ed through an S corporation and three affiliated limited liability companies and a real estate business conducted through that S corporation could be restructured on a tax-free basis so that the manufacturing operations are conducted through a single limited liability company and the real estate business is conducted through the S corporation