Taxation

Falcon Rappaport & Berkman has vast expertise in taxation, including the following areas of concentration.

Planning, Structuring & Compliance

The Internal Revenue Code continues to grow more complex, and at the same time, tax considerations have become central to transactions of all varieties. Since its inception, American taxation has had a significant impact on sectors such as real estate, venture capital, private equity, renewable energy, executive compensation, family business succession, charitable giving, and estate planning.

At FRB, our Taxation Practice Group interfaces with the firm’s other practice areas to find tax-optimized solutions for plans and transactions that are vital to our clients’ success. Whether resolving issues that threaten to delay a critical deal or navigating complex tax structures, we provide efficient strategies to ensure transactions move forward seamlessly and with favorable tax results.

 Clients consult FRB for tax planning, structuring, and compliance matters, including:

• Section 1031 Exchanges and Section 1033 Conversions
• Qualified Opportunity Zone Investments
• Tax-Free or Tax-Deferred Reorganizations, M&A, or Liquidations
• Fund Formation
• Freeze Partnerships
• Charitable Trusts
• Tax-Optimized Business Succession
• Opinions of Counsel
• Executive Compensation

International

As global business expands and travel becomes increasingly accessible, clients face tax challenges that span across the world. FRB’s Taxation Practice Group advises clients with international business activities, real estate holdings, investment portfolios, and family ties across borders. Advising on international taxation requires expertise in a range of statutes, regulations, treaties, and administrative guidelines. Our team brings together seasoned advisors with the knowledge and experience to guide clients through the complexities of cross-border tax rules, having counseled distinguished organizations and families on significant planning and transactions.

Clients seek our guidance on international tax matters such as:

• Cross-Border Corporate and Real Estate Deals
• International Estate and Gift Tax Planning
• Planning for FIRPTA
• International Fundraising
• Transfer Pricing
• GILTI and FDII
• CFCs and PFICs
• Compliance with FATCA

Controversies & Litigation

Dealing with federal, state, and local tax authorities can be stressful, time-consuming, and difficult. Tax issues often involve navigating the intricacies of multiple governmental systems, as well as understanding each agency’s policies and procedures. FRB’s tax attorneys are equipped to handle all aspects of tax controversy and litigation, providing a robust defense in disputes over unpaid taxes, tax liens, or differing interpretations of tax law. With experience working in government agencies, national accounting firms, and tax-focused boutiques, our professionals are well-positioned to deliver the best possible outcome for our clients. 

Our tax controversy and litigation services include:

• Defending Tax Planning and Structuring Techniques
• Unpaid Taxes
• Tax Liens and Levies
• Collection Due Process and Offers-in-Compromise
• Appeals and Litigation Before Administrative Law Judges

How Can We Help?

If you need expert guidance on tax planning, structuring, compliance, international matters, or tax controversies, our attorneys at Falcon Rappaport & Berkman are here to help. Contact us today to discuss your needs and find a solution tailored to your situation.