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    • OUR FIRM
    • BLOG
    • SERVICES
      • STATE TAX LITIGATION
      • STATE TAX ADVICE
      • STATE TAX PLANNING
      • STATE TAX POLICY
    • Our Team
  • OUR FIRM
  • BLOG
  • SERVICES
    • STATE TAX LITIGATION
    • STATE TAX ADVICE
    • STATE TAX PLANNING
    • STATE TAX POLICY
  • Our Team

STATE TAX PLANNING

Restructuring Analysis

Corporate Transactional Analysis

Corporate Transactional Analysis

We develop strategic plans to restructure business operations for a more tax-efficient structure by identifying tax inefficiencies through analyzing state and local tax filing positions, apportionment, tax attributes, uncertain tax positions, and valuation allowances. We provide recommendations to eliminate uncertain tax positions and avoid valuation allowances against tax benefits, while elevating the restructuring plan to maximize the benefits of filing elections, apportionment methods, and tax attributes (NOLs, credits, etc.).

Corporate Transactional Analysis

Corporate Transactional Analysis

Corporate Transactional Analysis

We analyze the state tax implications of transaction steps in corporate acquisitions, dispositions, and integration in the most tax-efficient way. We scrutinize the federal tax treatment of each transaction step, focusing on the state and local tax conformity (filing method, treatment of intracompany transactions, etc.). We scour for differences that can make a federal “tax free” transaction step taxable for state and local tax purposes

Representative Matters

Restructuring Matters

Restructured Vertically Integrated Product Business

We analyzed the vertically integrated business from the harvesting of raw materials to wholesale of finished product. Reviewed the intracompany transactions to analyze the tax implications of operating in a multi-entity structure. Identified inefficiencies that created unnecessary tax liability and proposed structural changes to eliminate tax inefficiencies.  Produced significant savings for the client.

Restructured Intercompany Debt

We reviewed the client's intracompany debt structure to identify tax inefficiencies related to the matching of income and expense. The evolution of the client's business operations resulted in the misalignment of the internal debt established to accurately match the income utilized to service the external borrowing. We established a plan to restructure the internal borrowing and a step-plan to achieve the desired result.    

Corporate Transactional Matters

Acquisition of Financial

We advised a large financial services firm on the acquisition of a strategic target. We worked with our client to analyze the proposed steps to accomplish the acquisition for state and local tax implications. We subsequently analyzed the most tax efficient way to integrate the business to maximize the tax attributes of the target business.  

Divestiture of Loss Business

We advised a large luxury retailer on the disposition of a loss business line to capture the benefit of the loss to offset profitable business lines. We were able to develop a plan to ensure the assets were utilized quickly and efficiently.  

State Tax Law LLC

contact@statetax.law

565 5th Avenue, 15th Floor

New York, NY 10017



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