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