Client Success

IRS Representation and Department of Revenue

• Negotiated an IRS offer in compromise for food industry client and settled federal tax debt of $506,749 for $116,000 after four rounds of negotiations, including valuation report from pre-selected qualified appraiser
• Successfully defended and minimized tax assessed in six-year NCDOR Sales and Use Tax Audit of healthcare service company with no prior sales or use tax filings and record retention irregularities
• Represented non-filers with delinquent tax returns come into tax filing compliance and become current with income tax payments due
• Negotiated favorable payment plans with the IRS and state tax authorities
• Reduced tax, penalties and interest in IRS Audit Reconsideration, resulting in refund of $121,187 on high-net-worth individual return
• Remediation of foreign asset and foreign bank account disclosures

Business, LLC and Mergers & Acquisitions

• Sale of environmental corporation to strategic buyer for $8 million
• Sale of veterinary practice and office building for $2 million transaction value
• Sale of plant and stone retail distributor to PE-backed company for $1 million
• Purchase of two-doctor practice for $2 million via bank loan
• Purchase of $1 million healthcare practice for PE firm backed by family office
• Buy-out of senior doctor for $500k in two-doctor practice via seller financing
• Sale of tea house for $700k transaction value
• Represented seller of franchised store in food industry
• Structured transfers of business ownership between spouses
• Represented startups in SAFE capital raise rounds
• Advised on tax-favorable structuring of group healthcare practices
• Designed and structured management company and corporate structure for healthcare practice
• Established U.S. operating entities and holding company structure for non-U.S. investors
• Designed asset protection LLCs for married couples and family-owned businesses
• Designed multi-member LLC operating structures for two- and three- business partner scenarios
• Drafted properly crafted independent contractor agreement assisted with proper implementation of contractor relationships
• Advised U.S. real estate investors on passthrough structure and buy-out
• Represented founders in negotiation and structuring of equity, employment and executive benefits packages
• Represented executives in negotiation and renegotiation of employment agreements and compensation packages

Tax Planning

• Designed tax-efficient structure for family-owned business for family in the highest tax bracket
• Designed business succession from parents to adult children while balancing optimized income tax consequences with parents’ cash flow needs in retirement
• Achieved deemed asset treatment via Section 338(h)(10) qualified stock purchase
• Achieved deemed asset treatment via Section 336(e) election for qualified stock disposition
• Achieved debt treatment for tax purposes in debt-equity scenarios
• Assisted with FIRPTA obligations and tax refund in sale of U.S. real property by non-U.S. sellers
• Identified red flags in tax due diligence of S corporation and C corporation target companies in stock acquisitions
• Advised on change of residency from North Carolina to Florida
• Analyzed tax profile of married couple transitioning through divorce and property division including asset and income discovery
• Analyzed tax consequences of casualty losses and involuntary conversion of real property

• We are committed to representing your best interests.
• We are highly organized. We manage information, timelines, and communication effectively.
• We keep our professional knowledge current and stay informed of hot legal topics.

• We ensure that your issue receives personalized attention.
• We treat our clients the way we would like to be treated.
• Our fee structure is guided by transparency.
• We are cost conscious in helping you manage your legal affairs.

• With our clients, we speak and write in plain English. We believe in common sense.
• We give each matter our full attention.
• Our work comes from word-of-mouth referrals.

• With practical and honest advice, we help our clients manage risks and accomplish your goals by making informed decisions.
• We act with professional integrity. We comply with and exceed the standards of applicable laws, regulations, and rules of professional ethics.