Tax Structuring

Overview


One of the first and most critical steps in any tax-planning process is the creation of effective financial and tax structures that can withstand the scrutiny of taxing authorities and regulatory agencies. McDermott’s experienced tax lawyers work with closely held businesses, publicly traded corporations and multinational enterprises to develop, document and implement cutting-edge solutions that help achieve business objectives and minimize tax liabilities.

Our closely held business group focuses on the unique tax, corporate and other issues facing privately held businesses and their owners, with a focus on family-owned businesses. Our corporate taxation team offers a broad range of tax structuring counsel to tax clients and their affiliates organized as C corporations for US federal income tax purposes. The Firm’s pass-through taxation lawyers advise on the use of partnerships, limited liability companies, S corporations, real estate investment trusts (REITs), and other pass-through entities in sophisticated tax planning.

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Results


Captives

  • Single-parent, multi-owner captive insurers and risk retention groups with the design and implementation of onshore and offshore self-insurance programs
  • A state university system with the structuring of a captive covering the legal, tax, and regulatory perspectives
  • Securitas Holdings, Inc., before the United States Tax Court in a significant victory with regard to captive arrangements against the Internal Revenue Service
  • Numerous multi-member LLCs with the successful resolution of a dispute before IRS Appeals involving the deduction of insurance premiums paid to a captive insurance company

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People


A diverse, global network of industry-leading talent committed to you and your vision.

Key Contacts


Kristen E. Hazel

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Thomas P. Ward

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Gary C. Karch

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