Notable Transactions

• Represented a private corporation and rendered a tax opinion in a $1,500,000 reverse like-kind exchange.
• Represented a private corporation and rendered a tax opinion in a $1,400,000 tax-deferred merger of Texas corporation into a Washington corporation.
• Represented a private Louisiana limited liability company in a $3,100,000 tax-deferred stock exchange.
• Advised a private Texas limited liability company on the use of net operating loss carryovers and issuing profits interests in connection with a $10,000,000 acquisition of a Delaware limited liability company.
• Represented a private Texas corporation in an IRS Private Letter Ruling request in connection with the conversion from an S corporation to a Texas limited partnership.
• Represented an individual in an IRS Private Letter Ruling request relating to substantial compliance in connection with a $1,500,000 non-cash charitable contribution.
• Advised an individual and rendered a tax opinion related to valuation and tax treatment of preferred units issued incident to the settlement of indemnification of stock purchase agreement.
• Represented a private corporation and its directors in a $500,000 Texas sales tax assessment and $46,000 settlement.
• Represented a limited liability company and its managers in appeal of New Jersey sales and use tax recovery penalty.
• Represented a limited liability company and its members in connection with appeal of proposed trust fund recovery penalty and obtaining refund of $100,000 overpayment of excise taxes.
• Represented a private corporation and its directors in connection with an appeal of a proposed trust fund recovery penalty of employment taxes.
• Represented numerous private entities in an IRS audit examination, audit protests, collection due process hearings and offers in compromise.
• Advised a private corporation on formation of a Turkish branch company, and branch profits tax effects pursuant to performance under a personal services contract in Turkey.
• Advised an individual on tax effects of a gift to a citizen of the United States of real property located Mexico from an individual not a citizen of the United States.
• Advised a private Texas subsidiary corporation of a Hong Kong public company on federal international income and Texas franchise tax effects related to a $30,000,000 sale of real property to a Florida-based real property development syndicate.