Federal Income Taxation of Corporations and Partnerships

PKJ’s tax practice encompasses tax advice relative to multiple aspects of taxation of corporations and partnership. We advise clients with respect to tax efficient entity formation, including advice with respect to choice of entity, the utilization of check-the box-elections, etc. We provide client advice regarding entity capitalization, including the choice of tax advantaged capitalization vehicles, analysis of tax consequences of the issuance or acquisition of debt instruments (including structured, contingent, or hybrid debt instruments). Our tax attorneys are seasoned transactional professionals and have assisted clients in all aspects of mergers, acquisitions, and divestitures, including advice on structuring domestic and cross-border taxable and tax-free corporate and partnership acquisitions and dispositions, analyses of acquisition transaction costs,  the application of consolidated return regulations, making Internal Revenue Code section 338 elections, analysis of limitations on the carryover of tax attributes such as net operating loss, post-merger integration planning and restructuring.