Experience Category: Tax Structuring

Tax Efficient Structure for Panamanian Development

Analysis and recommendation for tax efficient receipt of payments and profits for US citizen developing real estate properties in Panama business zone.  Application of S. 911 rules, debt and equity characterization and look-through vs. corporate taxation of profits on realization of project.

Application of Florida RPTT to Tiered Partnership

Analysis and advice relating to sale of upper-tier partnership interests in GP-LP structure involving Florida real estate and the application of real estate tax to transfers of upper-tier interests where lower-tier partnership held commercial Florida real estate.

Structuring legal entities

Structuring legal entities for new joint ventures involving existing investments and potential new investments. Considered tax optimization, securities law concerns, and complex agreement drafting of payment waterfalls upon interim and liquidating distributions.
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