Patterson Belknap's tax practice provides domestic and international for-profit companies, exempt organizations, high net worth individuals, and global private clients with sophisticated and bespoke counsel on tax planning, tax structures for business transactions, and tax controversy matters. Based on the particular needs and business objectives of each client, we analyze the merits of different ownership structures, counsel on the requirements of tax law, and address the long- and short-term implications of business transactions and investments in the U.S. and internationally.

We leverage the breadth of our tax law experience and our firm-wide collaborative approach to achieve results for our clients. Our tax attorneys are involved in every aspect of the firm's practice and work closely with attorneys in the Corporate, Employee Benefits, Employment Law, Intellectual Property, Litigation, Tax-Exempt Organizations, and Trusts and Estates groups to enhance our client service offerings. The team also counsels clients who come to our firm especially for its tax knowledge and ability to provide tailored solutions to tax goals. In addition, the team partners seamlessly with its wide network of international law firms to coordinate foreign tax planning and provide holistic tax counsel to our global client base. Our tax attorneys also represent clients in administrative proceedings, as well as in protests against proposed tax deficiencies.

Our Service Offerings

High Net Worth Individuals and Global Private Clients

In collaboration with the firm’s Trust & Estates group, our tax attorneys advise private clients on how best to achieve tax and personal planning objectives. We counsel wealthy individuals and families, founders and entrepreneurs, artists and art collectors, trustees, and others on preserving capital and restructuring wealth in a way that minimizes income, gift, estate, and generation skipping taxes. We have considerable experience in the use of trusts as a method for reducing both transfer and income taxes. In addition, our team advises clients on trust strategies designed to reduce or eliminate income tax due upon liquidity events by taking maximum advantage of the Qualified Small Business Stock (QSBS) exemption and other unique opportunities available to founders and investors residing in the U.S. and abroad.

We also help clients navigate both U.S. and foreign law to achieve an estate plan that accomplishes tax objectives of international families. We advise non-U.S. clients on efficient methods of wealth transfer to their U.S. children, as well as on the U.S. tax law treatment of structures not typically seen in U.S. domestic planning.

Tax Counsel for Non-Profit Organizations

Our tax attorneys counsel on tax-efficient means of charitable giving for our many clients who are committed to contributing the public good. The team regularly counsels tax-exempt clients on investment matters, including joint ventures with for-profit organizations, the potential excise tax on prohibited transactions, and other excise tax issues raised by such investments. We also help our tax-exempt clients review the tax implications of participating in real estate, venture capital, hedge fund, and other investments to minimize the tax on unrelated business income and to protect private foundation clients from excess business holdings and self-dealing excise taxes.

Business Transactions

The firm advises domestic and international companies, from early growth companies to mature businesses, on tax strategies through all stages of their business life cycle. From entity formation and capital raising, to mergers and acquisitions through restructuring and dispositions, our tax attorneys have experience advising on various types of business transactions.

Assisting with Reporting and Compliance

Our tax attorneys work closely with clients and their accountants and assist with general compliance questions, for both domestic and foreign clients. The team counsels clients under audit by the IRS and New York State, as well as many clients who have chosen to come into U.S. tax compliance through various IRS programs, such as the Streamlined Filing Compliance Procedures.  We represent clients at all stages of the audit process, including escalation to the level of the IRS Office of Appeals. We also prepare requests for private letter rulings and draft memoranda and opinion letters analyzing positions taken by our clients.