Tax planning and controversy resolution, written into the transaction from the first draft and held through the audit, the appeal, and the cross-border filing. Chicago, London, and Dubai work to one standard.
The tax outcome of an acquisition is decided when the step plan is drawn, not when the return is filed, and an examiner will read the two against each other. So we draft the position into the deal documents, reduce the reasoning to a memorandum, and align the returns and elections to that plan, so that the file an examiner opens tells the story the signing binder tells.
Firm facts · ReachA corporate and private-capital boutique with international reach: a principal office in Chicago, a second office in Oakbrook Terrace, offices in London and Dubai through partner firms, meeting locations by appointment in seven further US cities, and a partner network across ~51 jurisdictions on five continents. Founded 2013.
The planning work runs from entity choice through M&A structuring to the allocations and carried interest written into a fund. When capital crosses a border, the treaty position and the FATCA and FBAR reporting go into the same plan. On the controversy side, the firm has represented clients in matters before the IRS, through examination and Appeals, with the Tax Court available where a deficiency has to be contested before it is paid.
A tax position argued at the term sheet is a paragraph in a memorandum. Argued after a notice of deficiency, it is a lawsuit. We prefer the memorandum, and we write it to read well if it ever becomes an exhibit.
Representation in IRS examinations, administrative appeals, and federal tax controversy, with measured advocacy that narrows exposure and protects the record, coordinated with the firm's litigation practice where a matter proceeds to court.
Enter the practice: Audits & Tax Litigation →Tax structuring for business combinations, asset and stock acquisitions, carve-outs, and corporate restructurings, drafted into the deal terms so the structure holds at signing and survives the close.
Enter the practice: Mergers & Acquisitions Tax →Multi-state compliance, nexus analysis, apportionment, and state and local tax controversy for businesses operating across jurisdictions, where presence and liability are no longer the same question.
Enter the practice: State & Local Tax →International tax strategy for multinational businesses and individuals with foreign income, assets, and operations: treaty positions, structuring, and U.S. reporting obligations including FATCA and FBAR.
Enter the practice: Cross-Border & International Tax →Tax planning for real estate transactions and investment structures, including 1031 exchanges, alongside property tax assessment appeals, valuation disputes, and exemption applications across residential, commercial, and industrial holdings.
Enter the practice: Real Estate & Property Tax →Formation, governance, and ongoing compliance for tax-exempt entities, including 501(c)(3) charities, private foundations, and supporting organizations, with the recordkeeping discipline that keeps exempt status intact through an examination.
Enter the practice: Tax-Exempt Organizations →Estate and gift tax planning, trust taxation, and wealth-transfer strategy, generation-skipping and dynasty planning among them, integrated with the firm's private-client and asset-protection work so the plan reads as one document.
Enter the practice: Trusts & Estate Taxation →Tax planning for securities transactions, derivatives, financial instruments, and project finance, with the structuring that settles the efficiency of a capital-markets position before it is executed.
Enter the practice: Capital Markets Tax →Allocations, carried interest, blocker structures, and K-1 reporting, the partnership and fund tax mechanics drafted into the vehicle before the first dollar is called.
Enter the practice: Partnership & Fund Tax →Entity selection, transaction structure, and ongoing compliance shape long-term liability. An early decision compounds over the years, for better or worse.
An IRS examination or notice calls for prompt, considered representation. The early posture in a controversy often sets its ceiling.
The efficient outcome of an acquisition or financing is designed into the terms. Tax built into the first draft holds.
International planning is legitimate and increasingly common, but it carries full U.S. reporting, including FATCA and FBAR, and the penalties for getting it wrong are severe.
Tax-exempt organizations earn their status once and keep it through compliant operations and governance, which an examination tests.
Estate and gift tax planning carries wealth across generations. The structures that do it well are integrated with the broader plan from the start.
A partner leads every tax matter. We sit at the deal table with the corporate and private-capital teams so the tax position is drafted into the structure rather than negotiated against it later, and we run the same adversarial diligence the firm applies to every matter, mapping the questions a regulator will ask before it asks them. Where a matter touches the agency, we have represented clients in matters before the IRS.
Domestic and international structures, captive insurance, and family limited partnerships, the wealth preservation that the tax plan is built around.
Asset Protection →Wills, trusts, and generation-skipping plans, where transfer-tax strategy and the private-client plan become one document.
Estate Planning →Transactions, governance, and securities, the deal table where M&A tax and entity selection are decided.
Corporate →Before anything is signed, we model the transaction's tax consequences, from entity choice and basis to step-plan sequencing and treaty posture, and reduce the chosen structure to a reasoned memorandum that documents why the position holds.
The structure only survives if the filings match it. We align returns, elections, and disclosure statements with the step plan, so the paper trail the IRS eventually reads tells the same story the deal documents do.
When the audit letter arrives, we manage the examination as counsel, scoping IDR responses, protecting privileged analysis, and negotiating with the exam team while the substantive position stays intact.
If exam will not move, we take the dispute to IRS Appeals and, where necessary, petition the Tax Court before the deficiency is ever paid. Where it serves the client, a settled position is converted into a closing agreement that ends the question for good.
The return you file today is the trial exhibit you live with tomorrow.
Reviewed by Jonathan D. Herpy, Sr., Senior Partner · Last updated October 2026 · Educational overview · Not legal advice
Luxembourg is Europe’s principal cross-border fund domicile and a leading holding-company jurisdiction inside the EU single market, prized for its stability. Coordinated with locally admitted counsel.
Ireland is the only English-speaking common-law jurisdiction in the EU and Eurozone, a leading domicile for investment funds. Coordinated with locally admitted counsel.
Switzerland is a global center for private banking, wealth management, and international arbitration, valued for political stability. Coordinated with locally admitted counsel.
Singapore is Asia’s pre-eminent neutral hub for fund management, family offices, and cross-border dispute resolution, valued for its political stability. Coordinated with locally admitted counsel.
One partner is accountable for the whole matter, and you have that partner's direct line. Chicago, London, and Dubai work to the same standard.