Tax

Tax considerations shape nearly every major business decision, from choosing the right entity structure to financing a transaction, acquiring or selling a company, resolving a dispute with a taxing authority, or planning for the transition of a closely held business. Cullen and Dykman's Tax attorneys advise clients on federal, state, and local tax issues with a practical understanding of each client's business goals, operational needs, and long-term plans.

The firm's Tax attorneys work closely with colleagues across Cullen and Dykman's corporate, banking, bankruptcy, energy, nonprofit, trusts and estates, real estate, and litigation practices. That cross-disciplinary approach allows the Tax team to provide focused tax advice while helping clients move forward within the broader legal and business context of the matter.

Tax Services

• Business formation, entity choice, ownership changes, buyouts, dissolutions, and day-to-day tax planning.
• Tax structuring for mergers, acquisitions, investments, financings, rollovers, spin-offs, reorganizations, restructurings, and exits.
• IRS, state, and local tax audits, controversies, collection matters, settlements, and litigation.
• Tax reporting and withholding issues for financial institutions.
• Tax planning and compliance for tax-exempt, nonprofit, and religious organizations.
• State and local tax matters involving utilities, energy companies, renewable energy projects, real estate, and multistate business operations.
• Succession, wealth transfer, charitable giving, and closely held business planning in coordination with the Trusts and Estates team.

Business and Transactional Tax Planning

Cullen and Dykman's Tax attorneys help businesses evaluate tax considerations at every stage of the business life cycle. This includes choosing the appropriate form of entity, structuring operating and shareholder arrangements, evaluating S corporation elections, planning for contributions and distributions, and addressing the tax consequences of redemptions, buyouts, dissolutions, and liquidations.

Transactions, Restructurings and Financings

In mergers, acquisitions, recapitalizations, restructurings, and financing transactions, the Tax team works with Cullen and Dykman's transactional and restructuring attorneys, as well as clients' accountants, investment bankers, and financial advisors, to identify and resolve tax issues before they become transaction obstacles. The team advises on taxable and tax-free reorganizations, equity rollovers, spin-offs, pre-closing and post-closing tax issues, debt and equity financing, cancellation of indebtedness income, net operating losses, and other tax attributes.

Financial Institutions

The Tax Department regularly advises financial institution clients on federal tax information reporting and withholding obligations involving customer accounts. The team assists with questions involving backup withholding, foreign and domestic reporting obligations, IRS Forms W-9 and W-8, and Form 1099 reporting, including Forms 1099-A and 1099-C for acquisition or abandonment of secured property and cancellation of debt.

State and Local Tax

Businesses operating in New York, New Jersey, and other jurisdictions face a wide range of state and local tax obligations, including business taxes, sales and use taxes, payroll taxes, gross receipts taxes, transfer taxes, and other industry-specific taxes. Cullen and Dykman's Tax attorneys advise clients on planning, compliance, audits, administrative proceedings, and litigation involving state and local tax matters.

IRS and Tax Dispute Resolution

When clients face federal, state, or local tax audits or disputes, Cullen and Dykman's Tax attorneys focus on reducing exposure, resolving the matter efficiently, and protecting the client's broader business or personal objectives. The team represents clients in civil and criminal federal tax controversies, state and local tax controversies, audits, settlements, collection matters, and tax litigation.

Tax-Exempt Organizations Tax

Cullen and Dykman's Tax attorneys advise tax-exempt and nonprofit organizations, including religious organizations, educational institutions, public charities, and private foundations, on tax issues that arise throughout the organization's life cycle. This section is tax-focused and should link to the broader Not-for-Profit and Religious Organizations industry page for general nonprofit governance, operations, employment, real estate, litigation, and education matters.

Energy, Utility and Renewable Energy Tax

Cullen and Dykman's Tax attorneys support the firm's Energy, Renewables and Utilities team by advising sponsors, investors, tax equity investors, and utility industry participants on tax issues involving renewable energy projects and regulated utility operations.

Trusts, Estates, Succession and Wealth Transfer

The Tax Department works with Cullen and Dykman's Trusts and Estates attorneys to advise clients on tax issues involving wealth transfer, estate planning, charitable giving, closely held business succession, and transitions between generations. This coordination helps clients consider tax consequences as part of a broader plan for family, business, and fiduciary objectives.