Philip R. Hirschfeld

How Philip Helps Clients

Philip assists clients in a number of areas of tax planning (domestic and international) and tax controversy.

Specifically he has extensive experience in corporate tax matters, including M&A, acquisitions, contributions, distributions, liquidations, tax-free spin-offs and split-ups, debt workouts including consideration of cancellation of debt income and ways to eliminate such income, limits on NOLs, review of stock and asset acquisition agreements, special considerations and restructuring relating to Subchapter S Corporations. His real estate experience extends to planning for joint ventures, partnerships, LLCs and investment funds, review of offering memorandum, debt restructuring, like-kind exchanges, Opportunity Zone Funds and 1031 Exchange rules.

Philip is also known for his vast knowledge of international tax laws relating to cross border investments and planning for non-US persons coming to work or live in the U.S. and U.S. companies operating abroad, as well as advising clients on the tax aspects of such transactions. He focuses on outbound including Subpart F/CFC, PFIC, GILTI, foreign tax credit and impact of tax treaties and foreign law and inbound including FIRPTA, FATCA, withholding taxes, tax treaty relief and portfolio interest exemption, cross Border M&A (including §367) and use of debt financing.

Philip serves a wide array of clients, including high-net-worth individuals, corporations, mid-size businesses, real estate developers and entities focused on fund formation.

Philip is a frequent lecturer on cross border real estate investments, Qualified Opportunity Zone Funds, mergers & acquisitions, partnership tax planning and other topics for the American Bar Association, New York University, the Florida Annual Tax Institute and other groups and has authored several articles for numerous publications on similar topics.

What Clients Can Expect

Philip prides himself on finding solutions to unusual problems. His clients appreciate his breadth of experience, diverse background and that he can succinctly breakdown complex issues. They also appreciate his commitment to providing them with the best advice possible to help them reach their end goal without falling into any tax traps.

Outside the Office

When not working through complex tax planning, Philip can be found exploring his passion for photographing National Parks and the built environment.  He appreciates browsing art galleries, museums and other creative pursuits. 

Awards

• New York Metro Super Lawyers Rising Stars, 2021
• ABA RPTE Fellows Program, 2016-2018, Section honor for future leaders
• Nolan Fellowship, 2015-2016, ABA Tax Section honor for distinguished service and display of leadership