REAL ESTATE TRANSACTIONS

We develop effective and practical tax structures and solutions for owners, developers, lenders and investors.

  • Represented several corporations with more than $25 million at issue, contending that the gain they realized from the sale of a limited liability corporation or as the result of an election under Section 338 of the Internal Revenue Code was not subject to Pennsylvania state corporate net income tax.
  • On behalf of one of the largest banks in the United States, obtained an abatement of IRS penalties arising from the late filing of a foreign national's federal estate tax return.
  • Helped structure the worldwide operations of a group that specialized in the development, manufacturing and licensing of food supplements to minimize U.S. and worldwide tax.
  • Defended a foreign trust administered in Guernsey, Channel Islands, against a proposed 35 percent IRS penalty for the late filing of a form.
  • Structured the U.S. operations of a European-based fabric manufacturer and distributor to minimize U.S., Swiss and French taxes.
  • Assisted a U.S. franchisor of business systems to obtain, through the mutual assistance provision of the U.S.-Japanese income tax treaty, a refund of Japanese withholding taxes imposed on franchise payments.
  • Obtained a favorable private letter ruling from the IRS that reversed long-standing policy, allowing a spin-off of assets from a U.S. pension plan to a Puerto Rican plan with favorable tax consequences.
  • For many clients throughout the United States and internationally, designed solutions to implement business succession planning and individual estate planning goals.
  • On behalf of a global pharmaceutical company, secured a Pennsylvania state tax refund after convincing the Board of Finance & Revenue that a tax assessment against the company violated the U.S. Constitution.