Taxpayers spend more than 5 billion hours each year trying to comply with federal, state, and local tax laws due to their increasing complexity. Tax reform remains a priority in Congress, and when tax laws change, new issues will emerge, from complicated compliance challenges to planning techniques and how best to take advantage of potential new tax benefits with brief windows of opportunity.
Pryor Cashman’s Tax Group understands the nuances of ever-evolving tax laws. Our attorneys help clients navigate the opportunities and pitfalls, delivering sophisticated, cost-effective tax advice on a wide range of personal and business investment and transaction issues. With our clients’ personal and business objectives foremost, we carefully review all applicable financial and personal considerations to reduce their overall tax burden, mitigate tax liabilities, and stay on the right side of the law.
What We Do
Lawyers in our Tax Group provide creative and practical tax advice to individuals and entrepreneurs, nonprofits and foundations, investors, partnerships, and corporations on all corporate, partnership, compensation, and federal, state, and local tax issues affecting their investments, intellectual property, and other assets.
Corporate Transactions and Deals
In our corporate work, we create tax-efficient transaction structures and represent clients involved with venture capital, investment funds, and private equity. Clients include private and public middle-market companies, international corporations, and joint ventures in such industries as:
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Our firm structures and executes leveraged buyouts, spinoffs, split-ups and split-offs, subsidiary purchases, and recapitalizations. We advise investment managers in structuring and documenting private equity and hedge funds, and provide guidance on offshore investment vehicles and the most beneficial operational jurisdictions.
High Net Worth Individuals
Working with our Private Client Group, we handle tax, estate, and wealth planning for high net worth families, celebrities, entertainers, and athletes. We also help clients take advantage of partnerships, limited liability companies, and other pass-through vehicles to further their business and investment objectives.
Real Estate
Our tax lawyers partner with our Real Estate Group on a variety of real estate development projects and transactions involving commercial properties, such as office buildings, retail stores, shopping centers, hotels and resorts, residential and multifamily housing, cooperatives, and condominiums.
Additionally, our attorneys handle the tax implications of real estate partnerships, limited liability companies (LLCs), and real estate investment trusts (REITs), and structure tax-free like-kind forward and reverse exchanges, especially those involving tenancies in common. We play a major role in drafting joint venture arrangements, which often include complex tax and economic sharing arrangements, foreign participants, and, occasionally, Sharia-compliant structures.
Pryor Cashman helps to ameliorate the impact of New York State and New York City transfer taxes, mortgage recording taxes, and commercial rent and occupancy taxes. Further, we have substantial experience with land use issues, including representing developers before the New York City Department of Housing Preservation and Development to obtain tax exemptions for new construction and conversions to class A multiple dwellings.
International and Offshore
The Foreign Account Tax Compliance Act (FATCA) has considerably raised the stakes for offshore investment vehicles and other financial institutions. Our tax attorneys are well-versed in the requirements of FATCA and have counseled numerous clients on their obligations under this newly effective tax regime.
We also demystify the complex tax issues related to working, living, and investing internationally. Our lawyers advise multinational corporations and their executives, celebrities and athletes, high net worth individuals, and families with members and assets worldwide. We design structures to eliminate or minimize taxable income for tax-exempt and foreign investors doing business in the U.S. and have extensive experience developing and implementing tax-efficient structures for cross-border transactions and business operations, particularly those related to real estate development and film production and distribution.
Tax Controversies
Our tax lawyers counsel and represent clients in various stages of federal, state, and local tax controversies, as well as matters before the U.S. Tax Court, involving a variety of sophisticated issues, including transfer pricing. We advise on and handle audits, and seek resolutions of contested administrative matters, whether through formal and informal appearances or through litigation, and have counseled numerous clients concerning undisclosed offshore financial accounts and undeclared income.
