Kowan & Cordon’s tax practice is the engine that drives all of our transactions. We provide creative and sophisticated tax planning as a value added compliment to our other practice areas. We regularly work with U.S. and foreign clients to advise them regarding the international, federal and state tax aspects of a variety of corporate and partnership transactions, including mergers, stock and asset acquisitions, dispositions, spin-offs, and restructurings. We also provide counsel regarding the formation of and investment in a variety of private equity and other investment funds including major corporate venture capital, tax credit and real estate transactions.
We are highly experienced in advising foreign clients in connection with their U.S. real estate investments. Our focus is to assist the client in selecting the most desirable investment structure from both a tax efficiency and liability protection viewpoint. We design our structures to consider tax treaty benefits where available, privacy, and the portfolio interest exemption among other considerations.
Tax Credits and Deductions
A significant portion of our practice concentrates on the representation of investors, developers and syndicators nationwide in connection with tax-incentivized investments, including conservation motivated real estate funds, low income housing tax credits, renewable energy tax credits, historic rehabilitation tax credits, new markets tax credits, entertainment/film tax credits and other state specific credits. We also represent financial institutions with respect to loans secured by tax credits or property generating tax credits.
We provide audit and collection representation for individuals and businesses in matters involving the Internal Revenue Service and state and local taxing authorities. Our professionals routinely advise on matters relating to income, employment and sales taxes as well as FATCA reporting, trust fund liability and innocent spouse claims. We work directly with IRS and state auditors to negotiate tax settlements for our clients to include payment installment agreements, offers in compromise, and, in some cases, obtaining uncollectible status.
Executive Compensation & Benefits
Our tax advisory services include representation of companies, boards of directors, and executives in connection with executive compensation arrangements and employee incentive plans. We design, negotiate and draft a wide range of compensation arrangements to include employment and severance agreements, phantom equity plans, stock option plans, profits interests issuances and transaction bonuses, and compliance with Code Section 409A.