Tax

Realizing their objectives while minimizing their tax liabilities remains one of the key challenges for clients around the world. Their success depends on it.

Our Tax Group provides time-is-of-the-essence, state-of-the-art, partner-level advice on a wide range of complex tax issues. Averaging over 20 years’ experience each, our tax partners creatively address the entire spectrum of tax-related legal matters, from tax planning for sophisticated corporate reorganizations to the representation of clients in adversarial proceedings with the Internal Revenue Service and state tax authorities.

Regardless of the context or forum, our Tax Group identifies each client’s objectives and then designs efficient and cost-effective strategies for achieving them. We solve complex problems across a wide range of tax regimes for a wide range of clients, including:

  • International, federal and state tax planning
  • Tax planning for business owners, investors and high net worth individuals
  • Tax planning for mutual funds, REITs and other pooled investment vehicles
  • Tax planning for public charities and private foundations
  • Tax planning related to employee benefits and executive compensation plans
  • Public company tax compliance and representation
  • Representation in federal and state tax controversies, including administrative appeals and all phases of litigation

Clients

We serve corporate taxpayers across a wide variety of industries throughout the U.S. Our international work is often a result of our connections with other professionals around the world.

Many of our clients reflect our depth in the real estate, private equity, and financial services sectors. Our size and national reputation demonstrate our commitment to quality, an ability to design creative solutions to complex problems and the insight to understand and achieve our clients’ goals.

Delivery on Your Next: Case Studies

Delivering a global restructuring with a REIT conversion built on alternative, data assets

Challenge

A multinational, California-based data center company wanted to convert its assets into a public REIT to realize on tax efficiencies.

Getting to Next

Our team handled the REIT conversion, including obtaining an IRS Private Letter Ruling and rationalizing worldwide operations to maintain REIT compliance.

Results

The client successfully shifted assets to a REIT. Ameek Ashok PondaDavid KaplanBrian Hammell and Paul Decker supported this client in its REIT conversion and subsequent global restructuring, with a market capitalization of $25 billion.

Accolades

  • U.S. News Best Lawyers “Best Law Firms 2020 ranked Sullivan in Tax Law, National and Boston Metropolitan
  • Legal 500 United States 2019 ranked Sullivan in U.S. Taxes (contentious and non-contentious) and International Tax and praised the following individual tax attorneys: Ameek Ashok Ponda, David Guadagnoli, Joseph Donovan, Judith Edington, Caroline Kupiec, Joseph Darby III, Brian Hammell, Richard Jones, Daniel Ryan, David Nagle, Christopher Curtis, Amy Sheridan and Douglas Stransky.
  • Chambers USA 2020 ranked Sullivan in the Tax category in Massachusetts and awarded individual rankings for the following Sullivan tax attorneys: Ameek Ashok Ponda – Tax (Massachusetts) and REITs (Nationwide), David Guadagnoli and Amy Sheridan – Employee Benefits & Executive Compensation (Massachusetts).
  • International Tax Review’s Tax Controversy Leaders Guide 2020 recognized Richard Jones, David Nagle and Douglas Stransky as leaders in the area of tax.

Rankings (PDF)

  • Provide strategic guidance on corporate tax issues, including reorganizations, tax treatment of net operating losses, real estate transactions, cross-border transactions and the tax problems of closely-held businesses and their owners
  • Develop estate planning strategies for the tax-efficient transfer of wealth to the next generation
  • Conform the structure of employee benefits, equity incentives, executive compensation and retirement planning to all applicable tax requirements
  • Resolve controversies with federal and state tax authorities
  • Structure charitable giving and charitable foundations and trusts for maximum tax advantage, and offer guidance to tax-exempt entities
  • Ensure maximum tax advantage in the structure and operation of hedge funds, private securities partnerships, LBO and venture capital funds, regulated investment companies, real estate investment trusts and foreign corporations
  • Represented  a company and its shareholders. The Tax Department advised and represented the client in both criminal and civil proceedings on tax and Anti-Money Laundering issues in front of the District Court in Israel. The indictment that was filed refers to accusations regarding money laundering and tax fraud crimes in the amount of approximately NIS 150 million.
  • Represented numerous clients in Voluntary Disclosure Procedures, both in Israel and in the US. The department was successful in breaking satisfying deals with the Assessment Officers regarding the tax liability that was determined as part of the Voluntary Disclosure Procedure. The US tax treatment is done in collaboration with our firm’s tax department in the United States.
  • Represented Diebold Nixdorf  which is a Public Company traded in NYSE and is the manufacturer of Financial Machinery in connection to Israeli Operations. The Company is represented by the department on an ongoing basis, on various Financial Regulation and tax issues.
  • Represented the Israeli subsidiary of Brinks. The Company is represented by the department on an ongoing basis, on various Financial Regulation and tax issues. The Tax and Financial Regulation Department conducts legal opinions and files requests for pre-rulings from the Tax Authority and other Financial Regulators.
  • Represented the W.I.C group, a group of private companies in the Financial Industry. WorldCom Finance Ltd. which is part of the W.I.C group, is represented by the department on an ongoing basis, on various Financial Regulation and tax issues. The Tax and Financial Regulation Department conducts legal opinions and files requests for pre-rulings from the Tax Authority and other Financial Regulators.
  • Represented a company and its shareholders. The Tax Department conducted tax assessment against the tax assessor’s decision to charge the shareholders personally to pay a total of 5,000,000 NIS to the Tax Authority for the debt of a Company, on the basis of Article 119 A of the Income Tax Ordinance.
  • Represented private clients in the Magistrate’s Court and on negotiations in front of Assessor of their city regarding accusations for omitting income of more than ₪ 1,200,000.
  • Represented  several private people  in front of the Assessor of Gush Dan, Tel Aviv Metropolitan Area in many disputes.
  • Represented and assisted to a VC fund with handling Financial Regulations. Specifically FATCA and CRS Regulation requirements. The Tax Department is assisting the fund in implementing the required manuals and work procedures.

 

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