Federal Income Tax Update: Tracking Significant Changes

Michael provides tax and corporate law advice to businesses at all phases of operation, from initial business formation to disposition and all points in between.

Michael advises clients across virtually all areas of operation regarding U.S. federal income tax issues. He has represented U.S.-based, foreign-based, and multinational enterprises, providing advice in connection with acquisitions, distribution structures, and internal reorganizations, including complex cross-border transactions; U.S. Subpart F income and GILTI planning and analysis; foreign tax credit planning and analysis; tax treaty analysis; and other matters related to outbound and inbound U.S. tax planning. His representations have included business structures, operations, and investments by U.S. clients in, or by non-U.S. clients from, Europe, Canada, Latin America, and a number of other jurisdictions outside of the U.S. He also works with closely held businesses and their owners to develop and implement tax strategies that protect and enhance corporate value.

Michael has broad experience advising private funds, investment management firms, and investment industry professionals. In addition to tax counsel, he often renders advice regarding a host of fund formation issues for private equity and hedge funds. Further, he works with institutional investors, advising them on investments across a range of assets, including alternative investment products.

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics.