Contact: Thomas Humphreys or Paul Frankel
Morrison & Foerster’s tax practice encompasses federal, state and local tax law in the context of structuring transactions
and business enterprises, tax planning and consulting and representing clients in tax litigation. In addition, the firm is
highly skilled in related practice areas such as Employee Benefits and Executive Compensation, Trusts, Estates, and Estate
Planning. The firm has more than 40 full-time tax attorneys providing advice to the firm’s worldwide clients. Morrison &
Foerster’s tax attorneys regularly advise and represent clients in the following areas:
- Federal Taxation: the firm provides expert advice and counsel to both U.S. and non-U.S. corporations regarding all aspects of U.S. taxation,
including corporate transactions, mergers and acquisitions, U.S. taxation of multinational corporations, partnership taxation,
real estate taxation, financial transactions and the federal tax issues faced by specialized entities.
- State and Local Taxation: Morrison & Foerster is nationally recognized for its state and local taxation practice. The firm has represented clients
in virtually every U.S. state and has been involved in many of the most important cases in this area.
- Trusts, Estates, and Estate Planning: The firm represents individuals and fiduciaries in all aspects of estate planning and the administration of estates and trusts,
both foreign and domestic, including tax and estate planning for executives of public corporations and closely-held businesses.
- Employee Benefits and Executive Compensation: Morrison & Foerster regularly counsels clients regarding qualified employee benefit plans, including plan design and administration,
analysis of the income tax consequences of plan funding and distributions and application of ERISA fiduciary standards.
- Corporate Transactions and M&A: The firm advises both U.S. and non-U.S. corporations and investment banks on a wide spectrum of tax issues regarding mergers
and acquisitions, dispositions, joint ventures and strategic alliances; private and public offerings of debt and equity securities
and financial products; and leases of equipment and facilities. The firm also advises corporations and private equity funds
in connection with strategic and venture capital investments, leveraged recapitalizations and management buy-outs. Morrison
& Foerster has significant experience in tax planning for start-ups and early-stage companies, particularly new media and
high-technology companies.
- Litigation and Dispute Resolution: The firm represents clients in tax audit and dispute resolution proceedings regarding all types of federal taxes before the
IRS, the Tax Court, the Court of Federal Claims, and other federal trial and appellate courts. The firm’s practice also includes
a substantial expertise in state and local tax litigation.
- Partnership Taxation: Morrison & Foerster counsels partnerships and other non-corporate entities regarding a broad range of business transactions,
including roll-ups and restructurings; income and loss allocations and withholding tax issues; disguised sales and built-in
gains issues; and problems relating to allocation of liabilities for basis purposes, including loan workout situations.
