Entity structuring & rationalization
Compare entity choices, ownership structures, intercompany arrangements, and restructuring alternatives. Evaluate the tax consequences of simplifying redundant entities before implementation.
What the work can includeAn entity map and comparison of practical restructuring options.
Qualified small business stock
Assess potential Section 1202 eligibility, issuance history, business activities, shareholder requirements, and documentation. Integrate QSBS planning with fundraising, growth, and exit decisions.
What the work can includeAn eligibility assessment and recordkeeping roadmap tailored to relevant dates and law.
Mergers, acquisitions & exits
Evaluate transaction structure, tax diligence findings, purchase-price allocation, basis consequences, and after-tax proceeds. Coordinate with counsel, bankers, and the finance team.
What the work can includeA transaction tax issues list, structure comparison, and execution plan.
State nexus & multistate operations
Map activities, employees, property, and sales by jurisdiction. Assess potential income, franchise, and sales-tax obligations and coordinate compliance or remediation with specialists.
What the work can includeA state exposure matrix and prioritized next-step plan.
Cross-border tax
Analyze inbound and outbound structures, treaty considerations, withholding, FIRPTA, FDII/GILTI, BEAT, transfer pricing, and international reporting requirements. Coordinate planning and implementation with domestic and foreign advisors.
What the work can includeA cross-border tax issues map and coordinated planning and reporting roadmap.
Transfer pricing
Evaluate domestic and cross-border related-party arrangements, including state transfer pricing, transactions between non-consolidated entities, and REIT/TRS arrangements. Coordinate functional analysis, intercompany agreements, benchmarking, and arm’s-length pricing documentation.
What the work can includeA transfer pricing assessment and work plan covering pricing policies, supporting analysis, and documentation.
Pensions & owner benefits
Evaluate retirement-plan alternatives in the context of ownership, employee demographics, cash flow, and business objectives. Coordinate with administrators, actuaries, and benefits counsel.
What the work can includeA comparison of plan-design considerations and implementation responsibilities.
Joint ventures & capital structure
Analyze contributions, preferred returns, distributions, debt, equity, and ownership changes. Align modeled tax outcomes with the venture’s economics and proposed agreements.
What the work can includeA capital-structure model and tax-focused review of key deal terms.