We undertake domestic and international tax planning for businesses and provide tax advice in financial transactions. We handle a wide array of federal and state and local tax controversy matters before administrative bodies and in state and federal courts. Our clients are multinational corporations, financial institutions, international and domestic joint ventures and project developments, new business ventures, non-profit organizations and individuals. They include companies in traditional businesses such as energy, utilities, aerospace, pharmaceuticals, transportation, packaging, distribution, newspapers and publishing, technology businesses such as telecommunications, internet providers, hardware manufacturers and software developers, real estate owners and developers, professional sports franchises and biotechnology firms. We assist in all aspects of tax planning to enhance the tax efficiency of their activities and transactions, to limit their exposure to controversy, and to help them comply with applicable federal, state and local tax laws wherever they might do business. When disputes with the Internal Revenue Service or state taxing authorities do arise, we are well-equipped to handle all stages of tax controversy matters at both the administrative and judicial levels. In addition, we have considerable experience coordinating non U.S. tax audits and appeals. We also undertake worldwide tax restructuring to optimize cash flow and minimize worldwide taxes.

We have significant experience in the following areas:

• Domestic and cross-border taxable and tax-free mergers, acquisitions and spin-offs, partnerships and joint ventures. Specialized investment and financing vehicles such as investment partnerships, regulated investment companies (RICs), real estate investment trusts (REITs), real estate mortgage investment conduits (REMICs) and financial asset securitization investment trusts (FASITs).

• International tax planning and tax controversy services for a wide range of both domestic and foreign clients including advice relating to cross-border mergers, acquisitions and restructurings, cross-border joint ventures and financings, worldwide tax minimization, transfer pricing, foreign currency transactions, foreign tax credit and international tax treaty planning as well advice concerning international tax regimes such as the rules relating to controlled foreign corporations and passive foreign investment companies.

• Public and private debt and equity offerings both domestically and cross-border, including asset securitization programs for a wide variety of financial assets.

• Tax accounting issues including income and expense accruals, accounting for long-term contracts, accounting for R&D costs, capitalization versus deduction issues, and the handling of accounting method changes.

  Federal low-income housing tax credit issues with one of the nation's leading practices, including representation of equity investors, developers, yield guarantors, syndicators, housing authorities, and lenders throughout the U.S.

• Representation of equity investors and developers in transactions structured to qualify for the historic rehabilitation tax credit and/or the new markets tax credit.

• Federal tax administration and litigation before administrative bodies and in federal courts, including the U.S. Tax Court, the U.S. Court of Federal Claims, the federal district courts, bankruptcy courts, and appellate courts.

• State and local tax counseling and litigation in state trial and appellate courts and before administrative bodies in California and throughout the U.S.

• Representation of tax-exempt organizations in the full range of issues they face including formation and restructuring, obtaining and maintaining tax-exempt status, assistance in audits and internal investigations.

• Structuring complex like-kind exchanges including reverse exchanges, exchanges of large portfolios of real estate and exchanges of intangible assets.

• Tax planning for individuals and families with closely held businesses, including the structuring and use of various pass-through entities such as S corporations, limited liability companies and partnerships.

• Tax process and systems design and implementation.

• Financial statement effective tax rate planning and structuring, including coordinating with accounting firms providing audit services to reporting companies.

We regularly handle federal, state, and local tax controversies throughout the U.S. Most of our work involves representing corporations where we usually work directly with the company's tax department. However, we also represent partnerships, trusts, estates, individuals and other entities.

We assist from the earliest stages of the tax audits all the way through the various levels of judicial relief. At the audit stages, we assist the taxpayers in maintaining contemporaneous documentation, as well as in responding to the information and document requests from the taxing agency. We also have an abundance of experience in proceeding through the administrative appeal process to see if a favorable resolution can be obtained with minimal time and cost on the taxpayer's part. Indeed, we are successful in getting the matters successfully concluded in the audit or appeals stage at least 75% of the time. However, if a satisfactory resolution cannot be obtained administratively, we have the requisite experience to take the matter through the court system. We litigate numerous large and medium-sized cases in the Tax Court, federal District Courts, the U.S. Court of Federal Claims, the U.S. Courts of Appeal, the U.S. Supreme Court, and state tribunals from coast to coast.

Most of our tax controversy attorneys worked at some time in their careers with the Internal Revenue Service, the U.S. Department of Justice, the state attorney general offices, or the state tax authorities. Thus, they know how the case is viewed through the eyes of the government, in terms of policy, allocation of resources, publicity, settlement, and strategy. We often use this vast reservoir of practical experience to good advantage for our clients in obtaining the best possible results in the most efficient fashion.

Our state and local tax controversy practice is one of the strongest such practices in the country. We have attorneys who concentrate on state income and franchise tax, others on property tax, and still others on sales and local taxes. In the state income and franchise tax area, we represent some of the largest multinational companies, and we have experience and knowledge of unitary and water's edge questions. In the property tax area, we handle legal and valuation questions for all types of business with any and all kinds of property.

On the federal side, we handle nearly every kind of substantive issue which could arise, with perhaps the most experience in tax accounting issues, inventory, capitalization issues, credits, valuation, corporate transactions, debt vs. equity, and transfer pricing.

Many of our tax controversy attorneys also serve regularly on industry groups, testify before the pertinent legislative and administrative bodies, and assist in the writing of new laws and regulations.

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