Strategic Tax and Corporate Planning Services
Expert Tax & Financial Advisory
From technology startups or mid sized real estate developer to the large multinational company, PAI can advise on your tax and financial issues.
PAI has extensive experience in specialized in mergers and acquisitions, tax and securities matters. Having successfully counseled and advocated in hundreds of federal, state and local tax audits, protests and appeals, controversy, planning and transactional matters, both administratively and in litigation, involving multiple types of businesses, entities, trusts and individual taxpayers.
Select clients ranged from Ford Motor Company, Office of General Counsel, General Electric – Finance, AK Steel, Levi Strauss, SAIC, and Johnson Controls, to a variety of startups.
From technology startups or mid sized real estate developer to the large multinational company, PAI can advise on your tax and financial issues.
PAI has extensive experience in specialized in mergers and acquisitions, tax and securities matters. Having successfully counseled and advocated in hundreds of federal, state and local tax audits, protests and appeals, controversy, planning and transactional matters, both administratively and in litigation, involving multiple types of businesses, entities, trusts and individual taxpayers.
Select clients ranged from Ford Motor Company, Office of General Counsel, General Electric – Finance, AK Steel, Levi Strauss, SAIC, and Johnson Controls, to a variety of startups.
Our Expertise in Tax Planning Services
Mergers and Acquisitions (M&A) Tax
Pre-Transaction Structuring
- Entity formation and restructuring to achieve tax-efficient outcomes
- Tax-efficient holding company and acquisition vehicle structuring
- Domestic and cross-border transaction planning
Due Diligence and Execution
- Comprehensive tax due diligence and risk mitigation strategies
- Structuring of asset vs. stock purchases, Section 338 elections
- Handling deferred compensation, golden parachutes, and §280G issues
Post-Closing Tax Optimizatio
- Integration planning and compliance suppor
- Tax attribute utilization (NOLs, credits)
- Post-deal restructuring and planning for continuity
Estate Planning
Advanced Wealth Transfer Techniques
- Use of irrevocable trusts (IDGTs, SLATs, GRATs, QPRTs)
- Lifetime gifting strategies, including discounted valuations
- Charitable vehicles: CLTs, CRTs, and private foundations
Minimizing Estate and Gift Tax Exposure
- Use of the unified credit and GST exemption
- Planning for portability, basis step-up, and 2036 issues
- Coordination with closely held business succession
Intergenerational and Legacy Planning
- Structuring family limited partnerships and LLCs
- Estate freeze techniques and family office planning
- Harmonizing financial and non-financial legacy goals
Partnership and Strategic Alliance Planning
Formation and Structuring
- Drafting and negotiation of partnership/LLC agreements
- Capital account maintenance, §704(b)/(c) allocations
- Compliance with disguised sale and anti-abuse regulations
Tax Planning for Operations and Changes
- Special allocations, waterfall distributions, and tiered structures
- Planning for redemptions, admissions, and conversions
- Basis management and loss limitation planning
Joint Ventures and Strategic Alliances
- Structuring of complex domestic and international ventures
- Tax considerations for shared IP, services, and capital investments
- Cross-border structuring to minimize double taxation
Venture Capital Tax Planning
Fund Structuring
- Domestic and offshore fund structuring (LPs, blocker corps, feeders)
- Use of carried interest and management fee waiver strategies
- Analysis under §1202 (Qualified Small Business Stock) and §1045 rollover
Investor-Specific Planning
- Tax considerations for foreign, tax-exempt, and institutional LPs
- Unrelated Business Taxable Income (UBTI) blocking strategies
- Structuring founder equity and exit strategies
Portfolio Company Tax Strategies
- Equity incentive planning (ISOs, NSOs, RSUs)
- Loss utilization and R&D credit optimization
- Exit planning for IPO, acquisition, or secondary sale
Income Tax Planning
Individual Tax Optimization
- Strategic planning for wage, investment, and passive income
- Tax-efficient retirement and education funding strategies
- Charitable giving strategies, including donor-advised funds and CRTs
Business Entity Planning
- Tax treatment of flow-through vs. corporate structures o Compensation, fringe benefits, and bonus plans for executives
- Compensation, fringe benefits, and bonus plans for executives
- International income deferral and repatriation strategies
Income Tax Planning
Transition of Closely Held Businesses
- Structuring of buy-sell agreements with tax efficiency
- Planning for S corporation eligibility and basis step-up
- Integrating succession plans with estate and gift tax minimization
Executive Retirement and Exit Strategies
- Deferred compensation and SERP planning
- Installment sale, SCIN, and private annuity techniques
- Business continuity strategies in the event of incapacity or death
Family Business Solutions
- Governance models and multi-generational transfer techniques
- Equalization planning among heirs
- Use of life insurance and redemption techniques
International Tax Planning
Cross-Border Structuring
- Inbound/outbound structuring and entity classification planning
- Planning under GILTI, Subpart F, and PFIC rules
- Use of foreign disregarded entities, CFC rules, and tax treaties
Transfer Pricing and BEPS Compliance
- Documentation and compliance under IRS §482 and OECD guidelines
- Intercompany pricing models and dispute resolution
- Planning for cost-sharing and IP migration
Repatriation and Foreign Tax Credit Optimization
- Planning under §245A dividends received deduction
- Foreign tax credit utilization and limitation strategies
- Structuring for efficient profit repatriation and earnings stripping
Expatriation and Inbound Investments
- Tax planning for U.S. citizens renouncing or relocating
- FIRPTA planning for foreign investment in U.S. real estate
- Withholding tax analysis and treaty planning for inbound investors
Real Estate Development and Syndication Tax Planning
Entity and Deal Structuring
- Use of LLCs, REITs, and qualified opportunity funds (QOFs)
- Syndication structuring, promote/carried interest design
- Basis, at-risk, and passive activity loss planning
Development and Depreciation Planning
- Cost segregation studies to accelerate depreciation
- §1031 like-kind exchange strategies
- Capital gain harvesting and installment sales
Investor and Compliance Considerations
- Structuring for foreign and tax-exempt investors (FIRPTA, UBTI)
- Compliance with §704(c), disguised sales, and complex allocations
- Exit tax planning and waterfall distributions