Tax

SWA attorneys advise clients as to tax aspects of U.S. and international transactions. Our clients include multinational public and private corporations, partnerships, private equity firms, hedge funds, start-ups, and high-net-worth individuals.

Services provided include advising clients as to the tax aspects of fundamental business transactions such as:

  • domestic and cross-border mergers and acquisitions
  • dispositions and spin-offs
  • financings
  • capital markets and other securities transactions
  • formation of and investments by private equity, hedge funds and other partnerships

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.


Share: