Tax

Our tax attorneys are involved from the outset in every transaction that Finn Dixon & Herling undertakes. This approach helps ensure that the optimal structure is selected to serve the client's business objectives and that tax issues are quickly identified and advantageously addressed.  The core of our tax practice is providing planning and structuring advice to our transactional and private investment fund clients.  We also provide advice in connection with federal and state taxation of our clients' ongoing activities, and represent our clients' interests in federal and state tax controversies from the audit stage to the appeals and tax court levels.

Our tax attorneys are highly experienced in representing clients in the following areas:

Transactional

  • Structuring taxable and tax-free acquisitions and dispositions by public and private companies and private investment funds;
  • Advising on the creation of new business and joint venture entities;
  • Evaluating debt restructurings and exchanges and other balance sheet enhancement transactions for financially challenged companies.

Private Investment Funds

  • Advising fund sponsors on the structure and implementation of equity compensation arrangements;
  • Structuring arrangements among the principals of fund sponsors;
  • Structuring onshore and offshore hedge and private equity fund arrangements to maximize tax efficiency for domestic, offshore and tax-exempt investors;
  • Advising offshore hedge funds on U.S. withholding tax issues and compliance with the Foreign Accounts Tax Compliance Act ("FATCA");
  • Structuring hedge and private equity fund mergers and consolidations and secondary market transactions;
  • Evaluating and designing specialized hedge fund financial transactions and products; and
  • Advising funds and fund sponsors with respect to partnership allocations.
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