Corporate Tax

Tapping into SWA’s comprehensive tax expertise, clients benefit from our clear and unwavering commitment to supporting clients on their U.S. and international transactions. Our practical and commercial tax advice has been accumulated over many years of providing tax advice on domestic and international transactions, which include:

  • Domestic and cross-border mergers and acquisitions
  • Dispositions and spin-off
  • Financings
  • Capital markets and other securities transactions
  • Formation of and investments by private equity, hedge funds and other partnerships

Benefiting from this breadth of tax expertise is a client roster including numerous multinationals, both public and private, as well as partnerships, private equity firms, hedge funds, start-ups, and high-net-worth individuals.

Engagements Have Included

  • Developing optimum structure for merger of S corporation possessing substantial built-in gain with C corporation, in order to maximize utilization of net operating losses.
  • Structuring investment fund to invest in mortgage backed securities under Term Asset-Backed Securities Loan Facility (TALF).
  • Coordinating litigation involving involuntary condemnation of property with implementation of qualified reinvestment of proceeds.
  • Structuring expatriation of global telecommunications partnership.
  • Writing memoranda for law firm regarding tax implications of refund litigation
  • Developing novel investment mechanisms for implementation of series of Section 1031 like-kind exchanges with multiple parties.
  • Researching issue of acquisitions and related tax matters for law firm advising private equity funds.
  • Advising charities, private foundations, national trade associations and credit counseling organizations as to unique tax issues presented by particular nonprofit status.
  • Assessing opportunities and risks for tax-exempt organizations created by recently enacted Pension Protection Act of 2006.
  • Evaluating and providing compliance program for charitable foundation sponsored by publicly traded corporation.
  • Reviewing tax section of offering memorandum for international hedge fund.
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