Taxation

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

Planning, Structuring & Compliance

The Internal Revenue Code is one of the areas of the American legal system that seems to get ever more complicated as time goes on, and at the same time, tax considerations have seemingly become the fulcrum for deals of all varieties.  Since the inception of American taxation, it has had an extraordinary impact on the real estate industry, and now the worlds of venture capital, private equity, renewable energy, executive compensation, family business succession, charitable giving, estate planning and more.  FRB’s taxation department interfaces with the firm’s other practice areas to find tax-optimized outcomes for the plans and deals that can make or break a company’s future.  When tax issues threaten to hold up a transaction that can validate a client’s life’s work, the FRB team is there to implement tax-efficient solutions to ensure a deal goes through or an impasse gets surmounted.

Tax planning, structuring, and compliance matters for which clients consult FRB include:

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

International

As the world becomes more globalized and travel gets easier, clients’ tax needs span across the globe.  FRB’s tax department advises clients who have business activities, real estate holdings, investment portfolios, and family ties that stretch across countries, continents, and oceans.  Advising about international taxation requires analysis of statutes, regulations, treaties, and administrative guidance – and only a group of advisors with the knowledge, savvy, and experience to know the tangle of cross-border tax rules could confidently guide the way.  At FRB, we proudly bring together a group of experts with a history of counseling some of the most well-known organizations and families in the world about significant planning and transactions.

International tax matters for which clients consult FRB include:

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

Controversies & Litigation

Dealing with federal, state, and local tax authorities in the modern environment can be stressful, time-consuming, and difficult.  The endeavor can require not only a familiarity with the wickedly complicated tax systems of multiple governments, but also a knowledge of how each agency’s policies and procedures work.  Whether your issues involve unpaid taxes, tax liens, or differences in technical interpretation, FRB’s tax department can assist with all aspects of defending your rights and seeking a just outcome to your controversy or litigation matter.  FRB professionals have experience working for the government, national accounting firms, and tax boutiques concentrating exclusively in controversy and litigation, giving FRB the best chance to achieve the optimal outcome.

Tax controversy and litigation matters for which clients consult FRB include:

  • Defending Tax Planning and Structuring Techniques
  • Unpaid Taxes
  • Tax Liens and Levies
  • Collection Due Process and Offers-in-Compromise

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