Our Partnership Tax Services team works with a wide range of partnership and LLC clients intending to accomplish various economic deals. Our services focus on:
- Modeling of partnership agreements for tax consequences and to ensure tax allocations and distributions follow the economic deal arranged
Venture Capital
- Fund, Management Company, GP entities
- Blocker entities
- Effectively Connected Income Issues
- Unrelated Business Taxable Income Issues
- Carried interest planning
- Qualified Small Business Stock
- Warrant issues
- Capital account maintenance
- Foreign investment, PFICs/QEF elections and analysis, and other reporting issues
- Installment sales, earnouts, escrows
- Multi State tax returns
- Reportable transactions
- Side funds/affiliate funds
Real Estate
- 1031 exchanges
- Cancelation of debt income and planning
- Restructuring loans and guarantees
- Special allocations for promote or for depreciation or other tax benefits
- Maintenance of capital accounts
- Cost segregation studies
- 179D energy efficient improvements
- Redemptions and mechanisms for dealing with
- Tenant In Common (“TIC”) Properties and reporting for large TIC structures
Operating business partnerships
- Choice of entity analysis
- Professional services firms and the unique issues to their businesses
- Technology companies and maximizing credit flowthrough and utilization of losses
- Partnership unit grants (stock option equivalents for partnerships)
- Maintenance of capital accounts
- Tax planning related to the flowthrough of income and losses for owners
- Joint venture taxation
- M&A including assistance with due diligence and maximization of after tax cash for partnerships and their partners
- Conversions to corporation form
- Technical Terminations
- Multistate filings and composite filings on behalf of partners
S-corporations
Our S-corporation Tax Services team works with a wide variety of S-corporation clients in different industries. Our services focus on:
- Choice of entity analysis
- Utilization of losses at the shareholder level
- Late S-elections
- Private Letter Rulings for Late S-elections or inadvertent terminations of s-status (including due to an ineligible shareholder)
- M&A including assistance with due diligence and maximization of after tax cash for S-corporations and their shareholders
- Utilization and maximization of tax credits at the corporate and shareholder level
- Multistate and composite tax filings
- Built in Gain minimization strategies for C-corporations electing S-status
- Phantom stock plans and stock option plans for S-corporations
- Cancellation of Debt issues