Tax

Schnader’s Tax Practice Group is comprised of lawyers in our Philadelphia, Pittsburgh and New York offices who have broad experience in federal, state, local and international taxation, including sophisticated tax planning and structuring of transactions. We are ready to meet the tax-related needs of domestic and foreign corporations, partnerships, limited liability companies and individuals effectively and cost-efficiently.

Members of the group are prepared to handle the tax aspects of merger, acquisition and joint venture transactions; tax credit syndications; real estate investments and tax-exempt financings; as well as other types of transactions. Our group regularly handles federal tax controversies, including protesting proposed tax adjustments at the appellate level of the Internal Revenue Service and litigating cases in both the U.S. Tax Court and federal appellate and district courts.

Our attorneys also are highly conversant in a range of criminal tax litigation matters, and have represented numerous clients in state and local tax controversies in virtually every state.

Leadership in Specialty Areas

In addition, our Firm has substantial experience in virtually every area of international tax planning; bankruptcy and debt restructuring; employee benefits, including counseling clients on pension, profit-sharing and retirement plans; as well as in a wide range of state and local taxation law issues.

Our Attorneys

We understand that providing sophisticated advice and assistance requires an understanding of our clients’ business objectives and long-term goals. In each of the areas in which we practice, our lawyers make it their business to know and understand clients’ priorities, and are experienced in crafting advice and recommendations to fit those priorities.

Our attorneys have worked closely with clients in the following substantive areas:        

• Choice of entity
• Corporate taxation
• Creditors’ rights and bankruptcy
• Family law taxation
• E-commerce tax issues
• Employee benefits
• Employee stock ownership plans
• Estate and gift taxation
• Excise and employment taxes
• Executive compensation
• Exempt organizations
• Individual taxation
• International tax
• Leasing
• Like kind exchanges
• Mergers and acquisitions
• Natural resource taxation
• Partnerships/LLCs
• Qualified plans
• S-corporations
• State and local taxation
• Settlements
• Stock options
• Tax accounting
• Tax controversies
• Tax credits
• Tax-exempt financing

The breadth of our experience makes it possible for us to address the full range of tax-related issues that arise in sophisticated business settings. 

An Integrated Approach to Practice

Our attorneys provide an integrated set of legal services that weaves together various interrelated subsets of tax law. Examples include:

Mergers, Acquisitions and Joint Venture Transactions

Our Tax Practice Group has many years of experience in structuring and planning major corporate and partnership transactions, including joint ventures, mergers and acquisitions, divestitures, recapitalizations and leveraged buyouts. We help our clients structure their operations and transactions to take advantage of intricate tax-saving mechanisms.

International Tax Planning

Our attorneys routinely advise both U.S. and foreign clients on tax planning and the structuring of international transactions, including matters involving foreign investment in the United States, FIRPTA, income tax treaties, foreign tax credits, transfer pricing, cross-border leasing, Euromarket financings, foreign insurance operations and other matters.

Real Estate Taxation

We are regularly involved in structuring public and private real estate development projects, including tax credit syndications, as well as real estate investment and sales. Our clients include investors, developers, lenders and community development corporations.

Employee Benefits

Members of the group design and implement tax-qualified pensions and profit-sharing plans and prepare the necessary legal documentation. We counsel employers about the advantages and disadvantages of various types of retirement plans, including their financial, administrative and legal aspects. We design and prepare supplemental executive retirement plans (SERPs), often involving “rabbi trust” and corporate-owned or split-dollar life insurance. We also assist in the design, implementation and documentation of stock-option and phantom-stock plans as well as “golden parachute” agreements.

Bankruptcy/Debt Restructuring

Our attorneys advise corporations, partnerships and individuals on unique tax issues that arise in workout and bankruptcy situations, including discharge of indebtedness income issues and income issues pertaining to the use and carryforward of losses and other tax attributes.

Tax-Exempt Financings

We provide sophisticated advice regarding rebate compliance, change of use, debt modification and related matters involving tax-exempt financing. The Firm acts as bond counsel, underwriters’ counsel and special counsel in both large and small tax-exempt financing transactions.

Leveraged Lease and Equipment Financings

We represent clients in connection with leveraged lease and partnership equipment financings, including aircraft and vessel leasing transactions, asset securitizations and international financings.

State and Local Taxation

We provide national, state and local tax planning, audit support and response and related services in connection with the structuring and implementation of business reorganization plans, new business ventures and individual business transactions, audits and assessments of all states’ income, franchise, gross receipts, sales and use, employment, property, motor fuel, property transfer and other excise taxes. Our attorneys have maintained a tax practice in nearly all 50 states, where they have contacts with state tax administrators.  

Our Clients

The Firm has represented business entities in a broad spectrum of size, location and industry, ranging from large national and multinational clients in the transportation field, including United Parcel Service, Conrail and several major airlines; to tobacco, production and energy industries; and multistate, regional and local clients in the e-commerce, retail, health care and other service industries.