Corporate

Taxation

The experienced tax lawyers of Wiggin and Dana's Taxation Practice Group provide advice to businesses, individuals, estates, and trusts, in all stages of planning, implementation, compliance, and controversy resolution. Our attorneys provide stand-alone tax assistance to firm clients and work alongside attorneys in the firm's various Practice Groups.

Further, we have significant experience with international matters such as treaty interpretation, export incentives, CFCs and PFICs, the foreign tax credit, permanent-establishment issues, and use of offshore entities. We regularly represent individuals and businesses from other countries, including Sweden, the United Kingdom, the Netherlands, Belgium, Spain, Saudi Arabia, South Africa, Taiwan, the Republic of Korea, Venezuela, Brazil, and Colombia, in connection with their U.S. activities. We work in concert with counsel in multiple jurisdictions, with the aim of achieving the lowest effective overall tax rate.

We often assist our colleagues in the Private Client Services Department and the Family and Closely-Held Business Planning Practice Group, in planning and implementing transactions to minimize taxes. We also provide businesses and investors with tax-planning advice and representation for all types of family businesses and real estate transactions, including those involving more than one country.

We provide counsel on the various tax laws of New York State, New York City, and Connecticut as well as tax issues that can arise in other jurisdictions. Department head Peter H. Gruen currently serves on the Executive Committee of the Connecticut Bar Tax Section as Chair of the Real Property and Conveyance Tax Subcommittee.

In particular, our attorneys

  • Handle federal, state, and local tax disputes at all stages, including audit, administrative appeal, and trial. We regularly represent clients before the IRS as well as before the tax agencies of states and localities, particularly those of the State of New York, the City of New York, and the State of Connecticut.
  • Help clients who are starting new businesses or expanding into new markets determine the best legal form to minimize taxes and maximize legal protection; and assist clients with tax issues involved in various forms and levels of venture capital financing.
     
  • Work with accountants and members of our Corporate Department to provide tax advice in connection with the purchase or disposition of businesses, including tax implications of mergers and acquisitions, tax-free and taxable reorganizations and buyouts, spinoffs, consolidated returns, joint ventures, financial accounting, asset allocations, executive compensation packages, employment taxes, bankruptcies, and tax liens.
  • Provide advice on formation and organizational structure, regulatory compliance, compensation arrangements for private equity, real estate investment, and venture capital fund and other investment funds.
     
  • Assist clients in all areas of tax planning in connection with the acquisition or disposition of real property, including like-kind exchanges, workouts, discharge of tax liens, and bankruptcies.
  • Provide tax counsel in connection with the development of residential and mixed-use affordable housing projects utilizing low-income housing tax credits, historic tax credits, and Energy Tax Credits. We also have over 15 years of experience counseling clients in connection with obtaining private and public financing, including federal and state grants and loans (HOME, CDBG, Housing Trust Fund, Next Steps, Section 202, and Section 8 programs) for affordable housing and mixed-use projects.
     
  • Help businesses with multi-state activities address nexus issues and resolve tax disputes in multiple states.
     
  • Provide representation in local property-tax appeals through all stages, including meeting with the local assessor, appeal to the local board of tax review, and trial, if necessary.
     
  • Advise clients how to qualify for federal tax-exempt status and on the requirements for maintaining that status.