Tax

The Tax Team has broad-based experience handling international transactions, including planning for U.S.-based companies doing or seeking to do business outside the U.S. and foreign-based companies doing or seeking to do business in the U.S. The Team frequently advises and assists clients in structuring their operations in a tax-efficient manner, taking into account the tax rules on income sourcing, allocation of deductions, withholding, tax credits, and the application of the U.S. branch profits tax, subpart F rules, and Foreign Investment in Real Property Tax Act (FIRPTA). Our attorneys have also given in-depth consideration to issues raised by the allocation of income among related entities under Section 482 of the Code, including the application and interpretation of the temporary and final regulations implementing transfer pricing rules for transfers of tangible and intangible property. The Tax Team uses this extensive experience to counsel clients in all types of businesses and joint ventures with U.S. and foreign participants, often working with them to establish practical transfer pricing plans and guiding them through transfer pricing audits by, and appeals to, the IRS.

The Tax Team is regularly involved in analyzing state and local tax issues, including taxability of corporations, partnerships, trusts, qualified investment funds, and S corporations. The Team also provides counseling to governmental entities and 501(c)(3) organizations with respect to the issuance of tax-exempt bonds.

We have a wide range of experience in handling contested matters before all divisions of the Internal Revenue Service, including Collection, Examination, Appeals, and the Office of District Counsel, as well as all sections of the New Jersey Division of Taxation.

The Tax Team’s executive compensation and employee benefits practice has grown rapidly in response to extensive and steady changes in the law. Our attorneys have a broad range of experience designing, drafting, and administering qualified and nonqualified deferred compensation plans, stock option plans, and other forms of equity compensation. The Team regularly counsels clients on employee benefit issues that arise in corporate transactions and assists in the negotiation and treatment of employee benefit plans in the transaction documents. We also conduct audits of qualified retirement plans and health plans for COBRA compliance and assist clients in handling benefit claims for retirement, disability, and health plans, especially with issues of plan interpretation.

The Tax Team assists a growing number of nonprofit clients with obtaining and maintaining federal tax-exempt status and advises on the treatment of unrelated business taxable income, fundraising issues, and compliance with federal and state disclosure rules. We also work closely with the broader Corporate Group in counseling nonprofits on employment matters and on structuring affiliated entities consistent with their tax-exempt status.