Well-negotiated terms and conditions are essential to the success of any merger or acquisition. Tax considerations often play a pivotal role in the negotiation, structuring, and finalization of these transactions. When drafting the purchase agreement and related deal documents, it is critical that counsel thoroughly understand the tax implications of the proposed transaction. This knowledge is key to securing optimal tax outcomes for clients and ensuring that tax indemnification provisions are properly included to safeguard their interests.

Unlock unique financing tools for your clients’ real estate projects! Creative financing is essential for structuring successful real estate deals. Do you understand how to leverage various financing tools to maximize funding opportunities while navigating legal and regulatory considerations? Join leading experts as they explore innovative financing mechanisms that bring private capital to projects that serve private interests and public needs.

Advising business clients on the formation and ongoing operation of limited liability companies and partnerships requires not only a solid understanding of business principles but also a keen awareness of the complex tax issues these entities present. Even though you may not be a tax expert, you need the knowledge to identify and handle the business tax issues that your clients can expect to face.

A limited liability company’s operating agreement is more than just a framework for governance—it plays a pivotal role in determining tax treatment for both the LLC and its members. While many attorneys focus on ownership, decision-making, capitalization, and profit distribution, they often overlook the profound tax implications embedded within these agreements. A well-structured operating agreement ensures tax efficiency while aligning with the members’ broader business and management goals. Are you confident in your ability to navigate these complexities and provide your clients with the best possible tax guidance?

Business owners often relocate themselves and their businesses to different states, typically seeking more favorable tax conditions. The growing trend of changing domicile—the legal term for a person’s permanent home and primary residence—reflects this desire to optimize tax obligations. However, if your client is a business owner, relocating their personal residence alone won’t necessarily exempt them from tax liabilities in their previous state if your client's business continues to operate there. Understanding the intersection of domicile, residency, and business operations is essential for optimizing your client's tax position and avoiding costly mistakes.

It’s easy for real estate lawyers and other practitioners to be enticed by the siren song of 1031 qualified intermediaries (QIs) or artificial intelligence (AI). But proper tax planning requires qualified advisors who can ensure that your client’s 1031 transaction meets all legal and ethical standards. This presentation will offer topnotch analysis of tax law, comprehensive overview of the pertinent rules of professional conduct, and illustrative real-world scenarios to equip you with the knowledge to navigate the potential legal and ethical pitfalls inherent in these transactions.

Oftentimes in LLCs and partnerships, a compensatory partnership interest is intertwined with operational issues and dependent upon performance and profit. Structuring equity compensation plans that address business success as well as tax considerations is key to avoiding common pitfalls that can lead to disastrous tax consequences and disharmony between equity members. As counsel, you must be aware of the range of scenarios and traps and know how to appropriately address these complicated compensation issues when advising on compensation income.

Loper Bright and Corner Post, both landmark decisions, represent a sea-change for tax attorneys. Chevron deference no longer applies to tax regulations and even long-standing regulations are vulnerable to challenge, aided by an extended statute of limitations under the Administrative Procedures Act (APA). As a result, tax, partnership, and administrative law attorneys need to scrutinize regulations disputed with the IRS and Department of Justice, and transactional tax attorneys must keep the potential validity of IRS guidance in mind when planning transactions especially when Code provisions are silent. Although partnership provisions grant partners income, loss, debt and cash flow allocation flexibility, partnership anti-abuse rules in Subchapter K of the Code will continue to be used by the IRS when it suspects a reported tax position is abusive. IRS regulations challenges have already been filed, with more anticipated so it is increasingly important for practitioners to prepare their practice and clients, now! Register today for this critical webcast to learn what these decisions mean for partnership taxes, anti-abuse rules, and become an expert navigator of this uncertain legal landscape.

Navigating the tax burdens associated with major real estate transactions—such as property development, long-term ownership, build-and-sell strategies, and like-kind exchanges—can significantly impact deal structures and overall economics. Tax complications can quickly derail even the most promising deals. Join us for a comprehensive webcast specifically designed for real estate practitioners, and learn advanced planning strategies to smooth transactions, enhance deal outcomes, and minimize tax burdens.

Trusts are designed to protect beneficiaries – from themselves, other beneficiaries, creditors, and taxes. In some circumstances, it can be advantageous to designate, distribute, or appoint to another trust as a beneficiary of the primary trust. This beneficiary trust can be helpful for managing assets for minors or beneficiaries with special needs, providing asset protection, and maintaining privacy. It also allows for flexibility and customized estate planning strategies, and can be especially helpful in planning around overly broad state income taxes and source income rules that may otherwise affect the original trust or its beneficiaries. Join us for a look at the different circumstances under which you might want to name, distribute, or appoint assets to a trust as a beneficiary and the right types of trusts for each use.