Tax

Bochner provides strategic guidance to optimize tax outcomes for U.S. and non-U.S. businesses across diverse industries, including technology, commercial real estate, healthcare, consumer products, and manufacturing – as well as providing comprehensive counsel for individual tax clients.

We assist clients and ensure regulatory compliance in their business planning, corporate formation, and mergers and acquisitions, as well as the structuring of subsidiaries and tax-free mechanisms. Further, our services include counsel on a wide variety of U.S. tax issues and reporting requirements, rendering opinions, and providing a full array of tax form preparation services.

Business Tax Structuring and Transactions

Our team advises clients on tax implications for corporate formation, mergers, and financing activities across all stages of business lifecycle, ensuring alignment with long-term goals, including:

• Structuring F reorganizations for S corporations to prepare for mergers or capital raises.
• Forming U.S.-based subsidiaries for non-U.S. companies to streamline operations and facilitating other cross border transactions.
• Advising on tax-efficient mergers, acquisitions, and private securities offerings.
• Structuring venture capital financing and counseling borrowers and lenders on transaction terms.

Real Estate Tax Optimization

We guide developers, buyers, and sellers through the tax complexities of real estate ventures, transactions, and development, including:

• Structuring tax-deferred exchanges and tenancy-in-common transactions for commercial properties.
• Reviewing tax covenants and representations in real estate sales, leasing, and financing deals.
• Advising on federal and state tax compliance for property development and investment activities.
• Developing tax-efficient financing strategies for real estate borrowers and lenders.

Tax Compliance and Controversy Resolution

Our practice ensures clients meet U.S. tax obligations while robustly defending their interests in disputes with tax authorities, and, in litigation, leveraging rigorous advocacy in negotiations, mediations, and trials to secure favorable outcomes.

• Preparing and filing a full range of U.S. tax forms and providing reporting guidance.
• Advising on U.S. income tax consequences and treaty applications for cross-border activities.
• Representing clients in audits, appeals, and controversies before tax authorities and resolving complex, multi-party disputes.
• Representing clients in disputes over leases, titles, boundaries, zoning, and contracts.
• Rendering tax opinions to support business and investment decisions.