Our tax attorneys are highly experienced, thought leaders in their practice areas—many having begun their careers as tax attorneys with the government.  Our clients hail from a wide variety of industries, and include non-U.S. individuals and foreign corporations that are relocating, investing, or operating in the United States, as well as foreign financial institutions doing business in the U.S. through tax transparent branches.  Our inbound tax practice also focuses on foreign persons’ investments in U.S. real estate, U.S. stocks and securities, and rights to intellectual property (e.g. IP tax planning).  Our goal is to make sure our clients’ transactions and investments are structured as efficiently as possible, so as to achieve optimal business and tax results for the client.

Over the span of their careers, our tax attorneys have developed a global network of trusted foreign attorneys, certified and chartered accountants, and other professional colleagues with whom they regularly co-counsel on cross border deals and transactions.

Outbound Tax Planning

Besides advising on “inbound” transactions and investments, our tax attorneys are deeply experienced in structuring “outbound” transactions.  Outbound planning has become more challenging and complex since passage of the 2017 Tax Cuts and Jobs Act.  Our clients include high-net-worth U.S. individuals, employees, independent contractors, C-suite executives, corporations, partnerships, funds, and other financial institutions, operating and/or investing abroad.  We are highly experienced in navigating the complex and ever-changing web of U.S. and foreign corporate and tax rules, as well as nuances of the evolving network of bilateral and multilateral tax treaties—all sources of law that can apply, restrict, or, if carefully navigated, yield highly valuable tax exclusions, reduced rates, and other tax benefits.

Tax Controversy Matters

In addition to our transactional tax law practice, Tully Rinckey is highly experienced in tax controversy matters.  Our attorneys (many with government litigation and/or federal court clerkship experience) routinely help taxpayers resolve their tax disputes as advantageously as possible—whether the dispute is with the U.S. Internal Revenue Service (IRS), a state tax authority like New York’s Department of Taxation and Finance, a counterparty in a deal, or another jurisdiction.  We have built a solid record of achieving fair and favorable taxpayer settlements on a wide variety of complex and difficult issues.  Although most federal tax disputes can be resolved at the IRS administrative appeals level, we are prepared to go to court if we determine that doing would likely benefit the client.  Our experience includes litigating complex and novel tax issues in the U.S. Tax Court, the U.S. District Courts, and the U.S. Court of Federal Claims.

Private Letter Rulings and Tax Opinions

We have attorneys who are especially adept at writing IRS Private Letter Ruling requests on myriad issues.  IRS Private Letter Rulings are equal to an advanced private ruling on legal issues.  We also regularly write formal tax opinions for clients, which are the highest form of written legal advice.  Formal tax opinions are requested or necessary for a variety of reasons, but regardless of the underlying reason they are requested, they always provide some measure of assurance to the client in that they may clarify or even persuade tax authorities as to what the correct interpretation of a law or regulation is, or should be.  Tax opinions are often requested by clients that are issuing securities or want some form of tax penalty protection for a transaction, the effects of which are not entirely clear (the tax opinion is intended to clarify the likely effects to give the taxpayer more certainty).

New York State Sales Tax

With respect to our New York State tax law practice, we regularly advise clients on New York State Sales Tax issues (which have become more important in the wake of the U.S. Supreme Court’s 2018 landmark decision—South Dakota v. Wayfair, Inc.—in which the Court introduced an economic presence test, replacing the physical presence test.

Cryptocurrency

We are increasingly providing tax advice in the emerging and interrelated areas of cryptocurrency trading and formation, distributed ledger technology, and digital applications.  One of our tax attorneys was recently appointed to the American Bar Association’s Crypto Taskforce, which group of experienced crypto tax attorneys researches and drafts informative reports to the U.S. Treasury, advising U.S. tax officials as to what practitioners think the reporting and other tax rules with respect to the crypto and digital assets industry should be.  There are many rules applicable to cryptocurrency and digital assets being forged at the international levels; we make every effort to stay abreast of these developments, as well as market innovations.

Clean Energy

Another area in which we are increasingly providing more tax advice is in the emerging area of clean energy tax incentives.  Given the recent passage of the Inflation Reduction Act in August 2022, we will be increasingly focused on assisting individuals and businesses (large and small) on how to maximize the clean-energy tax incentives available under this new legislation, as well as under state and local laws.

Tully Rinckey’s core tax practices include the following:

  • Domestic Transactional Tax Planning
    • Fund and company formation
    • Real Estate Investment Trusts (REITs structuring and maintenance)
    • Mergers, acquisitions, spinoffs, split-ups
    • Partnership taxation
    • IP tax planning
  • International Tax Planning
    • Fund and company formation
    • Initial Entity Selection (check-the-box issues)
    • Inbound investments and operations (by foreign persons)
    • Outbound transfers, investments, and operations (by US individuals, funds, companies)
    • Puerto Rico and Puerto Rico “bona fide residency” issues; Act 60 planning; Audits
    • S.-Asia Transactions
    • Transfer Pricing
    • Intellectual Property Tax Planning
  • Formal Tax Opinions
  • Civil Tax Controversies & Trials
  • International Tax Controversies
  • International Tax Compliance (by individuals, corporations, trusts, partnerships)
    • Voluntary Disclosures
    • Streamlined Procedures
  • Tax Penalty Disputes
  • Appellate Tax Litigation
  • Cryptocurrency & Blockchain (including NFTs, smart contracts, reporting, planning, crypto fund formation)
  • New York State Sales Tax
  • New York Income Tax
  • New York Residency Issues
  • New York Low-Carbon Tax Incentives
  • Estate & Gift Tax Planning
  • Estate & Trust Administration

To schedule a consultation, contact us 24 hours a day, 7 days a week, at 8885294543 or info@tullylegal.com

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