Area of Practice

Tax Planning & Controversies

FBFK’s Tax Planning & Controversy practice helps businesses, investors, and high-net-worth individuals structure transactions, minimize tax exposure, and resolve disputes with confidence. Our team advises on entity structuring, M&A tax strategy, cross-border tax matters, and IRS audits, appeals, and litigation. We combine proactive tax planning with experienced advocacy to deliver practical, defensible solutions across the full lifecycle of a business or investment.

Our Approach

We design tax structures that evolve with your business. From formation to exit, we align entity selection, ownership, and compensation strategies with long-term growth, operational flexibility, and tax efficiency.

Who We Serve

  • Founders and entrepreneurs
  • Closely held and middle-market businesses
  • Growth-stage companies
  • Executive teams and leadership

We Advise Clients On

  • Choice-of-entity planning
  • Startup and growth tax structuring
  • Section 1202 Qualified Small Business Stock
  • Partnership/LLC formations, conversions, liquidations, restructurings
  • Corporate formations, conversions, liquidations, restructurings
  • Corporate and partnership reorganizations and divisions
  • Compensation and incentive planning for founders and executives

Our Approach

We help clients navigate global tax complexity with clarity, structuring cross-border operations and investments to reduce exposure and ensure compliance across jurisdictions.

Who We Serve

  • U.S. companies operating internationally
  • Foreign investors in the U.S.
  • Global families and business owners
  • Cross-border private equity and investors

We Advise Clients On

  • Structuring inbound and outbound investments
  • U.S. tax for foreign owners and operations
  • Treaty analysis, withholding, and permanent establishment issues
  • Cross-border M&A and post-transaction integration

Our Approach

We deliver integrated tax strategies that connect investments, ownership structures, and estate planning to preserve and grow wealth across generations.

Who We Serve

  • High-net-worth and ultra-high-net-worth individuals
  • Family offices
  • Investors and fiduciaries
  • Multigenerational families

We Advise Clients On

  • Income tax planning for owners and fiduciaries
  • Tax structuring for investment vehicles and holding companies
  • Integrating income tax with trusts, estates, and governance
  • Coordinating with estate and legacy planning

Our Approach

We take a coordinated approach to business and personal tax planning, helping owners align operational decisions with long-term financial outcomes and liquidity strategies.

Who We Serve

  • Owners of closely held businesses
  • Founder-led companies
  • Executive teams with equity participation
  • Family-owned enterprises

We Advise Clients On

  • Tax planning and restructuring for closely held businesses
  • Owner-level income tax planning
  • Compensation, distributions, and equity coordination
  • Structuring succession, liquidity, and reinvestment transactions

Our Approach

We manage disputes with taxing authorities proactively and strategically, aiming for efficient resolution while protecting our clients’ positions and minimizing disruption.

Who We Serve

  • Businesses under audit or examination
  • Individuals facing IRS scrutiny
  • Companies with complex tax positions
  • Clients seeking pre-litigation resolution

We Advise Clients On

  • IRS examinations and audits (including LB&I)
  • IRS appeals and administrative dispute resolution
  • IRS Chief Counsel National Office rulings and practice
  • Penalty defense, mitigation, and voluntary disclosures
  • Private letter ruling requests and IRS guidance
  • Pre-litigation controversy assessment and resolution

Our Approach

We handle tax disputes that arise after transactions close, aligning legal strategy with the original deal structure to protect value and resolve conflicts efficiently.

Who We Serve

  • Buyers and sellers post-transaction
  • Private equity firms and portfolio companies
  • Founders and management teams
  • Businesses facing audit or enforcement actions

We Advise Clients On

  • IRS challenges from acquisitions, restructurings, and exits
  • Partnership allocation, basis, and valuation disputes
  • Post-closing audits and enforcement actions
  • Disputes involving rollover equity and incentives
  • Coordinating transactional and litigation strategy

Our Approach

We integrate tax strategy directly into deal execution. Our team works alongside transactional counsel and investors to structure acquisitions and exits that maximize after-tax value and minimize risk.

Who We Serve

  • Private equity sponsors
  • Portfolio companies
  • Strategic buyers and sellers
  • Founders and management teams

We Advise Clients On

  • Buy-side and sell-side M&A tax structuring
  • Tax-free acquisitions and reorganizations
  • Partnership continuations in M&A transactions
  • S corporation 'drop and convert' F reorganizations
  • Taxable acquisitions and divestitures (Sections 338(h)(10), 336(e))
  • Investments, platform formations, and add-on acquisitions
  • Rollover equity structuring for founders and management
  • State and local tax

Our Attorneys

Location

Clear Selection

Capabilities

Clear Selection
Chair, Tax, Trusts and Estates Section
Attorney
Shareholder
Shareholder
Managing Partner
Shareholder
Proposition 19 Reshapes Property Tax Planning
How Proposition 19 Impacts Property Tax Planning
Read More
FBFK Law Expands Its Estate Planning and Tax Platform
FBFK Law Expands Its Estate Planning and Tax Platform
Read More
2026 Best Law Firms
FBFK Law Earns Regional Rankings in 2026 Best Law Firms® Ranked by Best Lawyers®
Read More