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RK&O advises clients on a range of federal, state and international tax matters that arise in connection with investments and structuring transactions, including acquisitions, sales and mergers. Our Tax practice collaborates closely with the other attorneys in our Corporate & Finance Transactions group to design tax-efficient deal structures and solve the complex tax challenges our clients’ face in the execution of their businesses. more +

We have particular expertise addressing the unique tax issues affecting tax-exempt and offshore investors. We’ve also cultivated a global network of local tax counsel, so we are regularly sought out by investors and funds seeking to maximize the overall tax efficiency of their international transactions.

Our additional tax experience includes:

  • Advising on the possible impact of cancellation-of-indebtedness income or reduction of tax attributes in connection with restructuring transactions.
  • Counseling on the restrictions governing the use of net operating loss carryovers following a bankruptcy or other restructuring.
  • Designing tax-advantaged compensation arrangements for corporations and partnerships and their employees.
  • Representing clients involved in tax controversies with federal and state authorities, at both administrative and litigation levels.

We are always searching for creative ways to allow our clients to accomplish their business objectives without sacrificing tax efficiency.


  • Numerous funds in creating tax-efficient structures for investments involving U.S. and other parties and multiple foreign jurisdictions.
  • Offshore investors concerning strategies to avoid income effectively connected with a U.S. trade or business.
  • Tax-exempt investors concerning strategies to avoid unrelated business taxable income.
  • A tax advisor in connection with an IRS investigation of tax-shelter opinions.
  • Companies and executives in connection with structuring tax-efficient compensation arrangements.
  • Minimization of cancellation of debt income and limitation of net operating loss carryovers in connection with restructurings.