U.S. Corporate and Business Law
At Juroviesky and Ricci LLP, we provide US legal services that enable our clients to operate in the United States. The pivotal services we offer to implement US federal, international, and state and local tax planning, include, but are not limited to, loan and financing agreements, transfer pricing agreements, shareholder agreements, share/purchase agreements, share/sale agreements, incorporations, LLC and Partnership formations, and all other US legal agreements that are needed to secure a tax favorable position for our clients.
U.S. Corporate Tax Planning
At Juroviesky and Ricci LLP, we offer sophisticated tax solutions to our clients in order to solve their complex corporate tax problems. We offer tax advice on every aspect of a transaction, including advice and solutions covering US federal, international, and state and local taxation.
We have experience in dealing with stock and asset acquisitions, and can recommend whether such transactions can be more advantageous as a taxable or tax-free transaction. At Juroviesky and Ricci LLP, we also have experience in completing US and multi-country reorganizations, mergers, and reverse mergers, and we recommend the best practices of ownership vehicle planning, forming corporate instruments, and effecting subsidiary transfers.
We also render tax opinions, secure rulings, and other technical advice memorandums to support our client’s tax position. This documentation serves to guard against attack and scrutiny from the Internal Revenue Service and other regulatory bodies.
U.S. Personal and Estate Tax Planning
At Juroviesky and Ricci LLP, we provide tax and legal advice to individuals and estates that serve to minimize our client’s US federal and state taxes on investments in US personal or real property. We also provide international income and estate planning to US and foreign individuals in order to lower our client’s worldwide tax liability.
U.S. State and Local Tax Planning
At Juroviesky and Ricci LLP, we have experience in rendering advice on the state and local tax effects of federal and international mergers, acquisitions, dispositions, refinancing transactions, and public offerings. We also offer overall tax planning and assistance within the conduct of tax audits, appeals, and litigation.
Juroviesky and Ricci LLP specializes in state tax nexus reviews from a state income and state sales tax perspective. We also have experience in recommending certain flow through entities (such as LLCs or Partnerships) as an alternative vehicle in order to save significant state income and/or franchise tax assessments.
We also advise on other state and local specific transactional taxes (such as special taxes on sales of assets or levies on telecommunication services).
International Tax Planning
At Juroviesky and Ricci LLP, we have experience in working with US and foreign multinational companies and providing them with cutting edge and creative tax solutions. We have experience in cross border mergers and acquisitions, joint ventures, spin-offs, restructurings, inter-company pricing, and financing and leasing transactions.
We advise our clients on the best possible international tax solutions from the initial stages of a company (i.e., a company’s expansion or acquisition), the day-to-day operation of the company, and its ultimate dissolution or liquidation. We implement cross border license and royalty arrangements, and represent US and foreign companies at Internal Revenue Service hearings, treaty hearings, and all other US tax litigation that may arise.
We specialize in Canadian businesses entering the US market. We advise on a multitude of issues from choosing the right business vehicle, the various financing options available, analyzing cross border transactions, offering operating alternatives, and advising on tax-efficient ways to structure cross border transactions.