Partnership, Corporate & Special Entity Tax.
Tax planning and advice for partnerships (general and limited), joint ventures, limited liability companies, corporations, and other business entities — covering formation, operation, acquisition, reorganization, and sale.
Fennemore’s Partnership, Corporate and Special Entity Tax Services assist with tax planning and advice concerning partnerships (both general and limited), joint ventures, limited liability companies, corporations, and other business entities. Our tax attorneys advise on the full range of tax issues relating to the formation, operation, acquisition, reorganization, and sale of business entities — California depth now backed by the resources of a full-service national firm.
What We Handle.
Partnerships & LLCs.
Recognized in Northern California for tax-related work for partnerships, limited liability companies, and other pass-through entities. We actively advise on:
- Partnership tax accounting
- Tax basis and FMV adjustment elections
- At-risk issues
- Substantial economic effect
- Phantom tax gain
- Withholding rules
- Partnership debt discharge (CODI)
- Recapitalization
- Partnership tax-deferred (Section 1031) exchanges
- Deemed sale rules
- Benefit planning
Corporate Taxes.
Both basic and sophisticated tax planning for corporate entities. In addition to the services provided for pass-through entities, corporate tax planning includes:
- Tax basis
- Minimization of Section 357(c) gain from excess debt formation
- Debt-equity characterization rules
- Taxable liquidations
- Tax-free reorganizations and mergers
- S corporation elections, built-in gains taxes, and passive activity taxes
- Professional service corporation rules
Beyond Day-to-Day Planning.
Our corporate tax work has also included:
Tax opinions
Government tax rulings
Tax assistance with financing
Acquisition tax due diligence
Attorneys With This Experience.
You May Also Need.
Federal Tax Services.
Federal income tax planning, compliance, and IRS controversy work.
State & Local Tax.
California income, franchise, sales, and employment tax planning and audits.
Nonprofit & Tax-Exempt.
Tax services and full nonprofit practice for public charities, foundations, and trade associations.
Real Estate Tax.
Tax planning for real estate transactions, holdings, and transfers.
Business Transactions.
Corporate practice and transactional work — the non-tax side of entity formation, M&A, and reorganizations.
Estate & Gift Tax.
Federal estate, gift, and generation-skipping transfer tax planning and returns.