TAXATION
Croke Fairchild specializes in the complexity of middle-market transactions and provides practical tax advice to support our clients’ deals.
Croke Fairchild represents clients in a variety of business and tax matters. We develop and implement creative yet pragmatic tax-sensitive strategies and solutions for complex mergers, sales and acquisitions, joint ventures, cross-border transactions, reorganizations, fund formations, sponsor led private equity financing rounds, and real estate transactions. Our practice includes:
- Structuring transactions to add after-tax value and meet business objectives
- Adopting wholistic transactional approach that considers entity and individual, income and employment, state and federal tax obligations
- Negotiating tax indemnities, tax representations, tax sharing agreements, and other tax-related aspects of mergers and acquisitions
- Ensuring tax-free issuance of incentive equity
- Minimizing state and local income tax costs of merger and acquisition transactions
- Positioning companies to take advantage of qualified small business stock (“QSBS”) benefits under Code Section 1202
- Effecting tax-free rollover transactions and utilizing non-recognition provision to the Code to enable tax-free restructurings
- Maximizing opportunities for basis step-ups in acquisitions and joint ventures
- Pre- and Post-transaction planning
- Performing due diligence on target entities
- Business entity selection
- Private equity fund formation
- Intercompany transfer pricing
- Evaluating executive compensation payments under Code Sections 280G and 409A