Tax

Rimon P.C.’s Tax team is comprised of seven partner-level attorneys, each of whom has more than 20 years’ experience in his or her specialty area. Our tax lawyers were partners in some of the United States’ largest law firms, and have represented clients on five continents and in all 50 states. We have been the tax lawyers on billion-dollar transactions and Wall Street IPOs, and before federal and state administrative bodies and courts. We represent some of America’s wealthiest families.

Each of us is committed to Rimon’s philosophy of responsiveness and efficiency. That means that the lawyer you hire will be the lawyer who is working for you — not a staff of mid-level lawyers. Moreover, we have 360 degrees of tax expertise, which means that we can advise you on almost any American tax issue you encounter. We invite you to learn more about our tax specialties below.

Related Practice Areas

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Employee Benefits & Executive Compensation

COBRA continuation
HIPAA privacy
Withdrawal liability
401(k) plans
Union contract negotiations
Pensions
Cash balance plans
Disability plans
Life insurance
ESOPs
Counsel top-level executives in the negotiation and documentation of their compensation and benefit agreements
Taft-Hartley and governmental plans
Post-retirement compensation
Health care arrangements (health, dental, vision, and nursing plans)
Designing and documenting compensation arrangements that may include: stock options, phantom stock, and other equity and non-equity elements
Analysis of investment decisions in conjunction with clients’ investment advisors
Mediation
Legal counsel on:
- Cash salary and bonuses
- Incentive stock options
- Non-qualified stock options
- Restricted stock plans
- Phantom stock agreements
- Limitations on tax-qualified plans
- Creative deferred compensation plans
- Supplemental executive retirement plans (SERPs)
Employment benefits
Employment contracts
Golden parachutes
Negotiated severances
Executive employment agreements
Incentive compensation arrangements
Deferred compensation
Employment disputes and litigation
Restrictive covenants and non-competition agreements
Enforcement of non-compete and confidentiality agreements
Separation agreements

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Estate and Gift Tax

Gift tax minimization through grantor retained annuity trusts (GRATs), family limited partnerships and other structures
Dynasty trust planning to avoid estate tax in successive generations
Income tax minimization through charitable remainder trusts and direct gifts to private family foundations
Preparation of estate tax returns and gift tax returns

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International Tax

Cross-border investments
International finance products
International transactions
Ongoing tax planning
International tax planning
FBAR disclosures
Trader taxation
Deferred compensation & stock options
Controlled Foreign Corporations (CFCs)
Structured finance
Mergers and acquisitions
Analysis of “tax shelters”
Tax treaties

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Non-Profit Organizations

Charitable giving
Finance – endowments and investments
Nonprofit governance matters
Nonprofit tax matters
Program-related investment (PRI)
Formation of private foundations
Advising board members and officers of public charities
Advising board members and officers of private foundations
Tax compliance for private foundations and public charities

Representative Matters of Rimon’s Tax Attorneys

Developed a strategy to transfer $75 million of family legacy real estate to a dynasty trust without incurring gift tax, and fully covered by generation-skipping tax exemption; the dynasty trust will protect that real estate from estate tax, creditor claims and divorce claims in perpetuity
Assisted clients on tax issues in all 50 states, on matters involving income taxes, franchise taxes, sales and use taxes, real property transfer taxes, and a variety of other state and local taxes
Counseled hedge funds, private equity vehicles, international mergers, startups, and international ventures
Worked with venture capital partners to transfer carried interests to irrevocable children’s trusts at the beginning of the fund when those interests were of modest value, and watched those interests grow in value to more than $10 million, thereby transferring significant wealth while using minimal gift tax exemption
Won 100% of $15.5 million income tax case involving tax credit, when the state argued that the available credit was limited to $20,000
Saved client from liability for many millions of dollars in uncollected hotel occupancy taxes in dozens of local and state jurisdictions nationwide
Developed multiple term of years flip charitable remainder trust strategy to hold extensive position in large public company that was a possible hostile acquisition target, so that client could (a) benefit the client’s private foundation when he chose by terminating one or more of the trusts early in whole or in part; (b) get the stock into a structure which would avoid capital gains tax on a sudden forced sale in a hostile acquisition; and (c) retain the right to cash flow from one or more of the trusts if he decided he needed it, by triggering the flip mechanism
Set up a tax structure for a U.S. company doing security related business in South Africa in connection with the 2012 World Cup, including joint venture agreements and employment agreements for U.S. and South African personnel
Set up a tax structure for a U.S. company’s investment and conduct of business in the telecom industry in France, Belgium, the Netherlands, United Kingdom, Democratic Republic of Congo, Sierra Leone, Guinea, and Argentina
Recovered VAT payments of U.S. company in Sweden, Belgium, France, and the Netherlands
Restructured Israeli company’s investments in Brazil and Poland through its Dutch subsidiary
Represented U.S. clients before the I.R.S. in connection with the I.R.S. Voluntary Disclosure Program
Created a charitable remainder trust to enable a client with a highly appreciated stock position to sell that stock with no capital gains tax, receive a charitable income tax deduction to shelter some of the capital gain for shares sold outside the trust, and receive a cash flow from the trust for life before the amount remaining in the trust goes to the client’s private family foundation on the client’s death
Created a GRAT (grantor retained annuity trust) with start-up company stock, enabling a company founder to transfer $10,000,000 to trusts for his children with the gift being valued at only $3,000