TAX A M u l t i - D i s c i p l i n e L a w F i r m

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1 TAX A M u l t i - D i s c i p l i n e L a w F i r m

2 TAX Troutman Sanders LLP The Tax Practice Group is comprised of attorneys who are experienced in the representation of clients whose activities require consideration of international, federal, state, or local tax matters. Several of the Group s attorneys are also certified public accountants and most have advanced degrees in tax law. The Group includes attorneys with prior experience in the Office of Chief Counsel for the Internal Revenue Service. Troutman Sanders tax attorneys provide clients with tax services and representation in all types of planning, transactions and controversies. The Tax Group s clients include public corporations, closely held companies, partnerships, limited liability companies, tax-exempt organizations, municipalities, government authorities, trusts, estates, qualified employee benefit plans, insurance companies, banks and real estate investment trusts. The Firm s tax attorneys structure complex business, financing, real estate, securities and other transactions. The Group works closely with the Firm s other practice groups, providing counsel and opining regarding the tax consequences of transactions, including bond issuances, joint ventures, debt modifications, mergers, acquisitions and other business combinations and divisions. In addition, the Group handles state and federal civil and criminal tax controversies in all administrative and judicial forums, from initial investigation through trial, and it has extensive experience in dealing with tax authorities at both the local and national levels.

3 International Tax Planning Troutman Sanders clients have an expanding international scope of business. To meet their needs, the Tax Group includes attorneys who are well-versed in international taxation. They also assist foreign clients with investments in U.S. businesses and real estate. The Firm s international tax attorneys develop and implement transaction structures designed to achieve worldwide tax efficiencies, and provide planning advice to minimize the adverse foreign tax consequences on repatriating earnings. In addition, they have structured numerous acquisitions of U.S. corporations and U.S. real estate investments on behalf of foreign persons. The Group has experience with transfer pricing planning and defense. Examples of their international experience include: Advising U.S. companies operating businesses and making investments in infrastructure development transactions overseas. Advising clients with regard to withholding tax planning and structuring royalty arrangements. Advising lessors, lessees and financiers in cross-border leasing transactions and international aircraft leases. Transfer pricing planning under Internal Revenue Code Section 482, minimization of foreign tax and U.S. earnings and profits, foreign tax credit utilization and treaty protection. Analyzing tax effective financing transactions. Advising several major Japanese and European companies on investments in real estate and operating businesses in the U.S. Advising clients of tax implications of transactions in connection with privatization efforts in numerous countries, including Portugal, Hungary, Ireland, Australia, Poland, Jamaica, The Bahamas, Hong Kong, Germany and the United Kingdom. The Group believes in a global approach to tax planning by creating structures which satisfy business needs while lowering worldwide taxes. They work with overseas advisors to understand the tax systems of the countries in which clients operate, and carefully consider increased or decreased offshore tax with the countervailing effect on U.S. taxes. As a result of this international work, they have developed strong working relationships with local law, accounting and consulting firms in a number of countries. This greatly enhances the Group s ability to ensure that all applicable tax laws are addressed. In addition, the Group s attorneys have developed extensive knowledge of the tax laws of certain foreign countries, including those that have, in effect, a treaty with the United States and those that do not. Tax Planning for Individuals, Business Entities and Tax-exempt Organizations Businesses and wealthy individuals often have to deal with extremely complex tax issues. The Firm regularly advises corporate and individual clients on general tax planning. The Tax Group represents all types of taxexempt organizations, and assists clients in obtaining and maintaining exempt status. The Group advises clients regarding lobbying activities and unrelated business income tax issues. Group attorneys work with real estate investment trusts in connection with joint ventures, including UPREITS, DOWNREITS and other investments and activities. The Group s exempt clients include traditional 501(c)(3)s, charities, private foundations and qualified plans. The Firm believes the best way to minimize a client s tax burdens is to provide effective tax planning strategies from inception of an idea through implementation. By taking a proactive, comprehensive approach to planning, Group attorneys are able to help clients manage tax consequences, reduce the risk of complications in the future, and in doing so, increase their profitability. In the planning area, the Group s experience includes:

4 Structuring business operations and investments domestically and internationally. Advising individuals on wealth transfer issues, including retirement plan distributions, charitable giving and estate planning. Providing advice regarding venture capital and other alternative equity investments. Structuring partnerships, limited liability companies and S-corporations. Structuring professional and personal service corporations. Providing advice regarding the structuring of investments by qualified plans and other tax exempt entities. This includes planning and implementing title holding company/qualified subsidiary structures for direct real estate holdings, and planning and negotiations for trust investments in private UPREITs and various alternative investment limited partnerships. Advising U.S. corporations in structuring multi-state operations. Structuring and implementing like-kind exchanges of real estate. Corporate, Real Estate and Financial Transactions The Tax Group has substantial experience in planning, structuring and negotiating the tax aspects of all types of business transactions. Group attorneys regularly structure, implement and opine regarding mergers and acquisitions, corporate divisions, corporate finance transactions, and corporate reorganizations and recapitalizations. The Tax Group works closely with the Firm s corporate and securities attorneys in connection with the issuance of tax-exempt bonds. The Firm has served as bond counsel and as counsel to the issuer, the underwriter, the lender and the borrower. The Group has significant experience in structuring various types of real estate investments, joint ventures and exchanges, including low-income housing tax credit projects, real estate investment trusts and like-kind exchanges. The Firm s tax attorneys regularly advise clients on the taxation of financial products and the tax implications of bankruptcies and workouts. They have assisted clients with project financing and leveraged leases. The Group s transactional experience includes: Counsel to a major electric utility on the tax aspects of acquisitions and dispositions in both the U.S. and foreign countries. Counsel to a heavy machine manufacturer in the acquisition of the stock of a British company for worldwide operations in the manufacture and sale of farm equipment. Counsel to a publicly traded real estate investment trust in connection with the structuring of joint ventures to acquire, develop, construct and manage commercial properties. Counsel to a privately-owned telephone and cellular services company in connection with its acquisition by a publicly-traded foreign company in a stock-for-stock transaction. Counsel to a privately held domestic paper manufacturer regarding the formation of a limited liability company (having a venture capital fund as the other member) to be used to acquire a facility in Canada. Counsel to a large qualified retirement trust in connection with its acquisition of interests in various alternative investment funds, including early and late stage domestic venture capital, international venture capital, and transition financings and special situations. Counsel to a major entertainment company in connection with acquisitions and financings. Representation of major international bank and state banking industry in obtaining an unprecedented ruling facilitating bank restructurings and multi-state banking.

5 Represention of novelty food products business in redomestication merger and formation of holding company of intangible assets as part of state tax minimization strategy. Counsel to an equipment manufacturer in connection with a tax exempt industrial revenue bond plant financing. Counsel to a charitable foundation in connection with financing one of the first mixed-income subsidized housing projects, including tax free bonds, low income housing credits and HUD subsidies. Given the broad resources of the Firm and the experience of thier tax attorneys, they are able to assist clients in all types of transactions. Tax Controversies The Tax Group has extensive experience in all areas of civil and criminal tax controversies. Group attorneys regularly handle both state and federal civil tax examinations, including handling the matter through the administrative appellate process and trial, if necessary. These attorneys also deal with matters involving standards of practice and preparer penalties; employment taxes, including employee/independent contractor status and responsible officer liability; sales and use taxes; and ad valorem taxes. Recent experience in representing clients in tax controversies includes: Successful representation of a publicly traded bakery company in connection with an Internal Revenue Service examination of the employment tax status of several thousand independent distributors (truck drivers). Successful representation of a publicly traded company in a highly publicized and lengthy federal grand jury investigation involving tax and ERISA issues. Successful defense of several publicly traded companies in connection with the valuation and ad valorem taxes of special purpose buildings. Obtaining favorable resolution for a bank in a dispute involving the proper tax treatment of bad debt reserves. This litigation was won on summary judgment before the United States Tax Court; subsequently the matter was settled in a manner favorable to the client. Successful representation of a publicly traded company before the United States Tax Court in a civil tax case involving proposed tax deficiencies of approximately $20 million and potential refund claims of more than $100 million. The matter included issues of form over substance, application of the claim of right doctrine, interpretation of the investment tax credit transition rules, and other issues. Successful representation of AT&T in the reported case of AT&T v. Collins, where the Georgia Supreme Court, in a case of first expression, sanctioned the unitary method of apportionment for AT&T. As a result of this victory, the Georgia Legislature amended the governing statute to specifically permit a taxpayer to choose the unitary method of apportionment. Counsel to localities in Virginia and Tennessee in negotiating lead settlements with Internal Revenue Service in nationally prominent black box bond transactions. Representation of state banking industry in structuring settlement with state tax authorities on issues arising under bank franchise tax statutes and related amendments to state bank tax laws. Representation of cellular telephone company in challenging application of state and local tax scheme to cellular telephone services, including successful litigation of pertinent tax issues. Representation of several national cable television providers in disputes involving state sales and income tax and local business taxes. Please call for more information on the scope of Firm services, particularly as they relate to your industry. Troutman Sanders is ready, willing and able to help you and your company obtain positive results.

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