Business & Cross-Border Tax Advisory

Tax, addressed with the structure.

Counselize advises businesses, founders, and investors on the tax consequences of entity choices, transactions, equity arrangements, and cross-border ownership structures.

Tax consequences follow from legal structure, so the two are best considered together. The choice of entity, the form of a transaction, and the way equity is granted each carry tax results that are easier to plan before documents are signed than to adjust afterward.

Counselize provides transaction-focused tax analysis covering entity classification and federal elections, tax-sensitive entity and ownership structuring, and the tax treatment of mergers and acquisitions, including asset-versus-stock transactions and basis consequences. For founders and investors, that extends to partnership and LLC allocations, carried interests, profits interests, equity compensation, and qualified small business stock analysis.

For cross-border businesses, Counselize considers international tax and information-reporting obligations, including FATCA, FBAR, and applicable treaty analysis, and foreign investment in U.S. businesses and real estate, including FIRPTA considerations. Written tax analyses and transaction memoranda document the position, with formal opinions provided where appropriate and separately scoped.

Scope

What this covers.

01Entity and electionsEntity classification, federal tax elections, and tax-sensitive entity and ownership structuring.
02Transaction taxM&A tax analysis, including asset-versus-stock transactions and basis consequences, coordinated with the underlying legal structure.
03Partnership and equity taxPartnership and LLC allocations, carried interests, profits interests, and equity compensation.
04Founder equityFounder equity planning and qualified small business stock (QSBS) analysis.
05International and cross-borderInternational tax and information-reporting considerations, FATCA, FBAR, and applicable treaty analysis, and foreign investment in U.S. businesses and real estate, including FIRPTA.
06Registrations and opinionsEIN applications and related federal tax registrations, written tax analyses and transaction memoranda, and formal tax opinions where appropriate and separately scoped.

Start with a conversation.