TAX POLICY AND BUSINESS TAX

Our tax lawyers are experienced in the development and advocacy of our clients' federal tax policy positions, and in consultations on a variety of business tax planning matters. We also serve the firm's clients on matters ancillary to regulatory issues and proceedings.

• For regulated companies, we often apply financial and economic principles in "crossover" situations. For example, in tax controversies, we help clients use legal and policy arguments incorporating both tax principles and regulatory policy considerations to support the clients' position. Similarly, we help regulated clients evaluate the tax consequences of corporate restructuring proposals in the context of their regulatory opportunities and constraints. At other times, we fulfill a more traditional role: for example, serving as tax counsel on leveraged leases of equipment and facilities, and on related public issuance of securities.
  
  
• In the biotechnology field, we have represented large and small companies, industry associations, tax-exempt organizations, and individual scientists. We have assisted in the full spectrum of federal and state income tax issues involved in forming and operating high-tech businesses, licensing, new executive compensation rules, and withdrawal and unwind issues.
  
  
• We have also been involved in federal corporate tax legislative initiatives. We understand the real world context of such efforts, including not only the duties and sensitivities of tax policymakers, but the internal processes by which the client determines its own priorities. We help the client to identify the effects of federal tax law on its situation, and to articulate why these effects harm not only the client, but also the public interest. We develop remedial proposals, based on sound tax and economic policy principles. We work as part of a team including in-house and outside lobbyists, and other consultants, and often are called on to present congressional staffs, either through position papers or in person, with the technical tax and economic policy features of particular proposals.