TW guides clients on how to plan and achieve financial objectives while maximizing tax advantages and minimizing tax burdens. We advise businesses, individuals and exempt organizations on all aspects of local, state, federal and international taxation. We provide tax planning, transactional assistance and tax controversy resolution. We also work with nonprofit organizations to obtain and maintain federal tax-exempt status and comply with state charitable solicitation regulations.
Federal Income Tax
Our counsel covers guidance to clients to:
- Tax Controversy: representing clients facing IRS tax issues such as tax levies and liens.
- Address the tax consequences of mergers and acquisitions
- Structure liquidations, spin-offs, recapitalization and transfers of ownership for maximum tax advantage
- Establish limited liability companies, partnerships, subchapter S corporations and other tax-efficient structures
- Develop and implement tax planning strategies at all stages of our clients’ development.
In the event of an audit, we counsel clients to determine the most appropriate course of action and are thoroughly familiar with the procedures required to reduce IRS penalties, obtain IRS private letter rulings, respond to IRS demands for documents and challenge administrative summonses.
Our international tax practice includes tax planning for businesses operating in cross-border transactions. TW has experience in representing large and mid-size corporations in international tax planning mergers and acquisitions, reorganizations and various other cross-border transactions. Our counsel also extends to advice on how to structure foreign companies inbound into the United States and also assist in structuring U.S. companies outbound into Europe and Central and South America. Our extensive experience in international tax includes involvement in the successful resolution of a tax controversy in Kazakhstan.
We provide guidance on the tax treatment of royalties, dividends and interest generated by foreign investments and of effects of international treaty provisions on the repatriation of those assets. Our experience interpreting and applying foreign tax laws make us uniquely qualified to counsel clients on the most advantageous strategies involving corporate structure and operation and the effect on taxation.
Tax Exempt Entities
The firm has extensive experience working with nonprofit organizations to obtain and maintain federal tax-exempt status and comply with state charitable solicitation regulations. We counsel clients from the formation of the non-profit entity to the yearly reporting requirements. A key concern for tax-exempt entities is maintenance of federal 501(c)(3) classification. We review and revise organizational charters and bylaws to ensure compliance with tax code requirements. We also help clients ensure proper filing of Form 990 (reporting on programs and finances) and Form 1023 (application for exemption). When tax-exempt clients are involved in business transactions, particularly with taxable organizations, we help them address potential effects on their non-taxable status. Additionally, TW assists its clients in establishing new corporate structures or leasing arrangements to handle unrelated business income tax issues.