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Tax Planning

Tax planning is a critical element of almost every transaction and investment and offers an opportunity to add value and minimize financial risk. The attorneys work closely with clients to meet objectives and to achieve optimal after-tax results.

Tax Controversy

Our attorneys have successfully handled a wide variety of complex Federal and California income tax audits and disputes.

Areas of Expertise

  • Tax consequences of the formation, operation and dissolution of business entities.
  • Mergers, acquisitions and divisions of business entities.
  • Cross-border (international and interstate) tax planning and transactions.
  • Transfer pricing with an emphasis on intercompany documentation.
  • Employee benefits and executive compensation.
  • Tax planning for high net worth individuals, including expatriations and residency determinations.
  • Obtaining advance rulings from the Internal Revenue Service.
  • Audits, administrative appeals and litigation involving the Internal Revenue Service, Franchise Tax Board, and State Board of Equalization.
  • Taxation of damages and settlement awards.
  • California property tax planning.
  • California sales and use tax compliance.
  • Taxation and reporting of foreign gifts.
  • Income taxation of trusts and estates.
  • Income tax basis management.
  • Taxation of intangible assets and digital assets (including cryptocurrency and NFTs).
  • Compliance with Foreign bank account reporting (FBAR) and Foreign Account Tax Compliance Act (FATCA) regimes.