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We understand that taxes directly affect the bottom line of every business, and our extensive experience allows us to provide our clients with creative and individually tailored solutions in order to achieve their tax planning objectives. We provide tax advice to many different types of clients ranging from individuals and closely-held businesses to multinational conglomerates. We advise our corporate clients on how to structure business transactions to achieve optimum tax advantages, including mergers, stock and asset acquisitions and dispositions, joint ventures and financings. We also advise on tax planning, such as utilizing net operating losses and credits and taking advantage of new legislation like the tax break for qualified production activity. In addition to publicly traded corporations, we represent small business clients on matters unique to them, including choice of entity, unreasonable compensation, and partnership and S corporation issues. Our firm has an active administrative and judicial tax practice. We prepare and negotiate ruling requests with the Internal Revenue Service and state tax authorities. We represent individual, corporate and other clients in connection with federal, state and local tax audits, including administrative appeals. We also handle sophisticated tax litigation in the federal and state courts. Representative issues at any of these levels include whether individuals are independent contractors or employees, whether a particular service is subject to sales tax, whether an expense must be capitalized or is deductible, when various types of income must be realized, and whether a particular federal tax is deductible for state tax purposes. Many of our clients are foreign individuals or corporations engaged in business or investment activities in the United States, and many of our U.S. clients are engaged in business or investment activities abroad. As a result, our practice extends to advising in connection with income tax treaties and other tax protocols and structuring business organizations and international transactions to minimize overall taxes. We also have experience in resolving issues with competent authorities, and we work closely with foreign law and accounting firms. Apart from more general tax matters, we service our clients on various specialized issues. We advise private equity funds on a whole range of tax issues, including the use of blocker structures to avoid effectively connected income for non-U.S. investors. In addition, we advise in connection with low income housing credits, regulated investment company issues, securitization of limited partnership interests, publicly traded partnership status, reverse and forward like-kind exchanges of real property, and other issues that arise from the many types of businesses that our clients operate.