Practice Area


Patterson Belknap's tax attorneys are involved in every aspect of the firm's practice. Our strengths include the breadth of our tax law experience and our firm-wide collaborative approach to achieving results for our clients. Our tax attorneys work closely with attorneys in the Corporate, Real Estate, Intellectual Property, Tax-Exempt Organizations, Trusts and Estates and Litigation Groups, and they counsel clients who come to the firm especially for its tax knowledge.

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, or address the long- and short-term tax implications of business transactions and investments in the United States and internationally. Our tax attorneys also have extensive knowledge of life insurance and other insurance products and the tax ramifications of various insurance programs. And, because many of our clients are committed to contributing to the public good, we counsel on tax-efficient means of charitable giving. In addition, the network of U.S. and international law firms to which we belong, the State Capital Global Law Firm Group, was named a Leading Law Firm Network in Chambers USA. Our tax attorneys frequently collaborate with the State Capital Global Law Firm Group and other international law firms on client matters. Our work in the industry has earned us recognition in publications such as U.S. News - Best Lawyers® survey of "Best Law Firms."

Meeting Tax Goals

Our tax attorneys provide advice on corporate, partnership, trust and individual tax matters, with an emphasis on coordinating clients' federal, state, local and foreign tax goals. Although their primary role is in income tax planning, they also represent clients in planning for other taxes (such as sales taxes, transfer taxes and private foundation excise taxes). Our tax attorneys also represent clients in court and administrative proceedings, as well as in federal, state and local audits and in protests against proposed tax deficiencies.

Structuring Business Transactions

The firm advises major domestic and international companies on structuring business acquisitions and dispositions in a tax‑efficient manner. Recently, for example, our tax attorneys structured such transactions as: a global alliance between a domestic corporation in the television broadcast industry and a United Kingdom counterpart for the purpose of creating satellite channels around the world, and a restructuring of a group of commonly owned corporations into a holding company structure in anticipation of an initial public offering.

From these larger transactions, our attorneys gain knowledge and experience that is invaluable in serving the needs of smaller, growing businesses. They often assist clients in creating joint ventures or in refinancing a business in order to develop new product lines, expand in new territories or acquire new subsidiaries.

High Net Worth Individuals

Our tax attorneys draw on their experience in structuring large business transactions to advise high net worth individuals on how best to achieve tax and personal planning objectives.

Assisting with Reporting and Compliance

The Tax Department routinely prepares requests for private letter rulings, technical advice memoranda and determination letters, as well as in drafting memoranda and opinion letters supporting positions taken by our clients on their tax returns. We work closely with clients and their accountants to establish internal reporting procedures and make sure that their computer systems produce the type of data needed for the preparation of their tax returns. We have become increasingly involved in litigation focusing on state and federal estate tax issues.