The tax attorneys of the Morris James' Private Client Services group represent individuals who own their business or profession, are high-level executives in Fortune 500 companies, university professors, or from any one of a number of other career paths, but in each case recognize the value gained by a proactive and coordinated tax plan for their future. In addition, we represent clients who are already faced with difficult and complex tax issues that have often escalated to the stage of a tax controversy.
Working closely with clients and their advisers, we help to develop and implement inter-generational wealth transfer strategies, including the sale of assets to family members, private annuity transactions, the use of family partnerships and limited liability companies, and discounted-value transfers utilizing grantor retained annuity trusts, grantor trusts, and other structures.
Morris James' attorneys counsel individual clients in retirement planning, tax-advantaged structures for life insurance, and strategies for the tax-efficient disposition of pension and profit sharing plan assets, IRAs, and non-qualified deferred compensation arrangements. We work frequently with clients and their advisers in developing plans for charitable giving, including charitable gift annuities and charitable remainder trusts.
We give proactive advice to clients and their professional advisers in a variety of federal and state tax matters, developing individualized tax-saving strategies, giving guidance in tax return preparation questions, and assisting in the interpretation of tax statutes, regulations, and administrative rulings. Our clients include U.S. citizens and residents who maintain financial and business interests outside the United States, as well as non-citizens with financial and business interests within the United States. In this realm, we often provide counsel on complex aspects of tax equalization analysis and relevant tax treaties.
Our attorneys also represent clients in proceedings involving federal and state tax authorities and administrative agencies, including the Internal Revenue Service, the U.S. Department of Labor, and the Delaware Division of Revenue. We have assisted many clients in obtaining favorable private letter rulings from the National Office of the Internal Revenue Service, and have provided successful defenses in income tax, employment tax, gift tax, and estate tax audits in the courts, as well as before administrative agencies.
Working directly with clients within our Tax, Estates and Business Practice and in conjunction with our colleagues in other transactional areas of the firm, we develop and implement tax-deferred exchanges of real and personal property assets. Structuring tax-deferred exchanges requires precise planning and timing. We recognize both the tax compliance and transactional aspects involved to navigate these complexities in order to qualify the transaction to proceed on a tax-deferred exchange basis.
Morris James’ individual clients, working with attorneys in other practice areas of the firm, benefit from our tax knowledge in a variety of matters. We provide guidance in structuring spousal support obligations and property settlements in divorce proceedings, assist our colleagues in implementing tax-efficient strategies for real estate acquisitions, dispositions, and financing, and support our litigation teams on varying tax aspects of corporate and bankruptcy issues inherent in these matters.
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