Representing buyers or sellers with mergers, acquisitions (equity or assets) and dispositions, foreign direct investment, joint ventures, corporate and fund formations, private placements, and tax-free reorganizations.
Regularly form and structure LLCs that include profits interests and various waterfall distribution provisions.
Assist clients with S corporation pre-transaction planning, pre-transaction restructuring of buyer or seller corporate structures, and planning for the sale of personal goodwill.
Assist with tax planning involving individual, C corporation, S corporation, partnerships/LLCs, executive compensation, and international tax matters.
Represent individual taxpayers and various entity types in IRS exams/audits, appeals negotiations, and Tax Court litigation (conservation easements, micro-captives, partnerships/LLCs, valuation matters, etc.)
Represent clients in state tax controversy matters before the Alabama Department of Revenue.
Assist with large tax collections matters, penalty abatements (domestic and international), and various types of IRS voluntary disclosures.
Assist clients in navigating various OFAC sanctions programs, such as those concerning Russia, Iran, and Venezuela.
Provide guidance on product classification under the EAR and the ITAR and analyzing whether those products can be exported to various jurisdictions, such as China; tailoring corporate policies and compliance programs; providing employee training; and advising on related third-party due diligence.
Advise on pre-transaction CFIUS-related diligence; determining whether a CFIUS filing is mandatory or prudent; filing CFIUS notices and declarations; negotiating conditions for CFIUS approval, including national security agreements designed to protect U.S. national security; and restructuring companies that are subject to ongoing CFIUS monitoring following committee approval.
Represented over 100 U.S. and foreign taxpayers in every iteration of the IRS’s Offshore Voluntary Disclosure Initiatives, including the streamlined procedures.