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US and International Taxation
Our Tax Department offers sophisticated tax guidance to U.S. and foreign business entities and individuals in all aspects of Federal and state income taxation. Our attorneys offer creative solutions tailored to achieve the business objectives of the particular transaction or matter in the most tax-favorable manner, taking into account the risk tolerance of the particular client. We are always mindful of the principle that the most aggressive tax position is often not ultimately in the best interests of the client. As an example of this, our Tax Department has been in the forefront in discouraging our individual and corporate clients from participating in the various questionable “tax shelter” investments which have been recommended in recent years by other firms and which have been the subject of adverse determinations by the courts. We are
regularly being retained to negotiate settlements with various Federal and state tax authorities on behalf of a number of those investors in their efforts to minimize the adverse financial and tax consequences resulting from these investments.
Most recently we have been retained to provide advice to a substantial number of clients relating to the ongoing IRS investigation of
U.S. taxpayers owning undisclosed offshore/foreign accounts at Swiss and other banks.
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