
Contacts
- 716.848.1511
- 716.848.1468
Hodgson Russ tax attorneys provide guidance on the full range of U.S. federal business and personal tax issues for clients, including multi-national Fortune 500 companies, public companies, privately held businesses, emerging technology companies, venture capitalists, investors, business owners, executives, and high-net-worth taxpayers.
Our mission is to provide creative solutions to allow our clients to achieve their objectives in an ever-changing economic environment. We identify tax issues and find responses that take into account all relevant business, personal, and family considerations.
Experienced Business Tax Attorneys at Hodgson Russ
Our attorneys are service-oriented and practical. We don’t simply provide tax advice when asked — we offer creative solutions that help avoid problems.
Hodgson Russ has been awarded a prestigious National “Best Law Firm” ranking by Best Lawyers/U.S. News & World Report in the category of Tax Law and an additional Metropolitan Tier 1 ranking in Tax Law.
Our Business Tax Services and Areas of Expertise
Mergers and Acquisitions
Hodgson Russ attorneys structure and negotiate acquisitions, mergers, and divestitures of businesses.
We have extensive experience with transactions that include taxable and tax-deferred asset and stock acquisitions by domestic and international companies. The scope of our extensive experience includes the following areas:
- Domestic and international mergers and acquisitions
- Sales and divestitures
- Canadian and U.S. business transactions
- Corporate reorganizations
- Corporate recapitalizations and redomestications
- Tax-effective financing structures
- Spin-offs
- Use of “Section 338” elections
- Executive compensation and severance issues
Joint Ventures, Partnerships, and Limited Liability Companies
Hodgson Russ attorneys represent clients in the tax issues associated with conducting business and investment opportunities through partnerships, limited liability companies, and other flow-through entities. We have advised our clients in establishing and operating joint ventures from large corporate entities to start-up ventures among individuals. We provide guidance on:
- Debt and equity financing issues
- Structuring for preferential returns
- Real estate ventures
- Cross-border business activities
- Emerging technologies
- Distributions
- Reallocations
- Basis issues
Corporate Tax Matters
Hodgson Russ attorneys advise and assist clients on business tax matters of all kinds. We have extensive experience structuring complex reorganizations of public and privately held corporations, rendering opinions in connection with acquisitions and securities offerings, and representing corporate clients in spin-offs and liquidations. Our attorneys regularly counsel clients on tax issues arising from regular business operations. We have significant experience handling the tax problems of closely held corporations, including S corporations.
We advise our clients with respect to:
- Operational issues under both Subchapter S and Subchapter C of the Code S corporation qualification
- Reorganization and tax-deferred structuring
- Business formation and capitalization
- Personal holding company and accumulated earnings tax matters
- Consolidated group issues
- Taxation of distributions
- Taxation of hybrid securities
We have wide-ranging experience in providing tax guidance to real estate developers. We counsel investors on the structuring and tax consequences of investment in real estate ventures.
Our attorneys have extensive experience involving tax issues related to:
- Structuring and negotiating real estate ventures
- Cross-border activities, including FIRPTA issues
- REITs
- REMICs
- Partnership liability issues, debt restructuring, debt forgiveness, and workouts
- Low-income housing tax credits
- Like-kind exchanges, including involuntary conversions
- Tax-exempt financing
Tax Controversies
Hodgson Russ attorneys represent clients in tax controversies from the auditor’s examination level through the appellate process and in the court system. We have successfully handled a wide variety of controversy work, including:
- Business taxation issues
- Personal income tax litigation
- Estate and gift tax controversies
- Cross-border matters, including transfer pricing disputes
Tax Planning for High-Net-Worth Individuals
Hodgson Russ attorneys frequently advise business owners, senior executives of public and private companies, entrepreneurs, venture capitalists, and high-net-worth individuals on tax issues related to business and investment holdings.
Our counsel includes the following:
- Personal income tax planning
- Charitable gift planning
- Estate planning, including business succession planning
- Tax issues related to international business holdings
- Compensation issues, including stock options and other equity-based compensation, phantom stock, deferred compensation, rabbi trusts, golden parachutes, and retirement plan issues
- Expatriate planning, including tax issues related to immigration and visa matters
Tax Planning for Nonprofit and Charitable Organizations
Hodgson Russ attorneys regularly advise clients on transactional, operational, and compensation planning for nonprofit clients, including large health care organizations, educational institutions, and social service providers. We also devise creative structures for the acceptance of gifts by these clients and Hodgson Russ’s many foundation clients.
- $142 Million Joint Venture for Construction of Senior Housing Projects
- $275 Million Manufacturing Company Merger
- $300 Million Joint Venture in Heat Transfer Industry
- 155-Store Supermarket Chain Purchased by Senior Management
- Acquisition on Behalf of France-Based Automotive Parts Manufacturer
- Assisting Canadian Startup Expansion Into the United States
- Buffalo Sabres’ HARBORCENTER Project
- Cegedim SA Represented by Hodgson Russ in Its Acquisition of Dendrite International, Inc.
- Cross-Border Limited Partnership Structuring for U.S. & Canadian Citizen-Owned Business
- Ensuring U.S. Tax Compliance for Multinational Equity Plan
- Federal and State Tax Considerations for Nonresidents Owning U.S. Real Property
- Federal Tax Issues Pertaining to Sale of Building With Outstanding Tax-Exempt Bonds
- Formation of $100 Million REIT to Acquire Assets in the Hospitality Industry
- IRS Voluntary Disclosure Assistance for Canadian Client
- Merger on Behalf of Privately Held Confectionery Company
- Private Placement Memoranda for an Independent Oil & Gas Company
- Representation of Fortune 1000 Manufacturer in Interests & Real Estate Acquisition
- Represented European-Owned Client in Major U.S. Acquisition
- Special U.S. Tax Counsel in Connection With the Redomestication of a U.S. Company
- Successful Tax-Free Pro Rata Spin-Off of Medical Device Company
- Tax Planning for the U.S. Operations and U.S. Acquisitions of a Large Austrian Company
- Tax-Free Spin-Off & Reorganization of Statewide Brokerage Business
- U.S. Tax & Corporate Counsel for Multinational Joint Venture Group of Entrepreneurial Companies With Ties to Hong Kong, Canada, and the United States
- U.S. Tax Counsel to Large, Publicly Traded Canadian Company
- U.S. Tax Counsel to U.S. Company With Respect to Redomestication to Canada for Security Law Reasons
- U.S. Tax Planning for U.S.-Citizen Owners of Canadian Enterprise
In the News
- October 26, 2020
- Buffalo Business First, January 18, 2019
- Tax Analysts, October 10, 2018
- WBFO, April 14, 2014
- Canadian Manufacturing, December 23, 2013
- Law360, September 11, 2013
- September 9, 2013
Press Releases
- Hodgson Russ Press Release, August 19, 2022
- Press Release, November 18, 2015
Publications
- Tax Notes State, April 10, 2023
- Hodgson Russ Federal-International Tax Alert, March 18, 2021
- Hodgson Russ Equine Alert, December 31, 2020
- Hodgson Russ Federal-International Tax Alert, December 28, 2020
- Hodgson Russ Federal-International Tax Alert, December 28, 2020
- Hodgson Russ Federal-International Tax Alert, November 19, 2020
- Hodgson Russ Federal-International Tax Alert, November 19, 2020
- Hodgson Russ Federal-International Tax Alert, May 5, 2020
- Hodgson Russ Federal-International Tax Alert, May 1, 2020
- Hodgson Russ Federal-International Tax Alert, April 14, 2020
- Hodgson Russ Federal-International Tax Alert , March 27, 2020
- Hodgson Russ Federal-International Tax Alert , March 26, 2020
- Hodgson Russ Tax and Labor & Employment Alert, March 24, 2020
- Hodgson Russ State & Local Tax Alert, March 21, 2020
- Hodgson Russ Federal-International Tax Alert, March 19, 2020
- Tax Notes State, November 18, 2019
- Tax Notes State, September 23, 2019
- Business Tax & International Tax Alert, July 30, 2018
- Tax Alert, March 8, 2018
- Agricultural Alert, February 21, 2018
- Federal and International Tax Alert, December 18, 2017
- Tax Alert, December 7, 2017
- Newsmax Media, November 14, 2017
- Tax Alert, November 13, 2017
- Tax Alert, November 6, 2017
- Business Tax & International Tax Alert, March 15, 2017
- Estate Planning Alert, August 18, 2016
- State & Local Tax Alert, May 2, 2016
- STEP Connection, Toronto Branch Newsletter, April 2016
- Tax Alert, January 22, 2015
- Buffalo Law Journal, January 8, 2015
- Hodgson Russ Alert, February 7, 2014
- Federal/International Tax Alert, January 4, 2013
- Federal/International Tax Alert, September 5, 2012
- Federal/International Tax Alert, March 6, 2012
- Federal/International Tax Alert, January 12, 2012
- Federal/International Tax Alert, December 13, 2011
- Unreported Offshore Accounts? New Yorkers Can Avoid State Tax Penalties Through Voluntary DisclosureTax Stringer, May 2011
- Federal/International Tax Alert, February 9, 2011
- Federal/International Tax Alert, October 8, 2010
- Federal/International Tax Alert, August 23, 2010
- Life Sciences Alert, June 23, 2010
- Federal/International Tax Alert, March 4, 2010
- Federal/International Tax Alert, February 15, 2010
- October 7, 2009
- Business Entities, July/August 2009
- Federal/International Tax Alert, June 22, 2009
- The Bottom Line, May 2009
- 2009
- October 17, 2008
- International Tax Alert, June 19, 2008
- Canadian Tax Highlights, September 1, 2007
- December 15, 2006
- Buffalo Law Journal, July 14, 2005
- Buffalo Law Journal, March 24, 2005
Presentations & Events
- Austin, Texas, May 3, 2023
- Embassy Suites – Syracuse Destiny, November 2, 2022
- Washington Hilton –1919 Connecticut Avenue NW, Washington, DC 20009, November 1 - November 2, 2022
- Doubletree by Hilton Hotel Binghamton, October 26, 2022
- ABA Section of Taxation 2022 Fall Tax MeetingDallas, TX, October 13, 2022
- March 17, 2022
- August 25, 2021
- July 27, 2021
- June 2021
- June 29, 2021
- April 21, 2021
- February 25, 2021
- December 8, 2020
- October 22, 2020
- Wednesdays, May 6 - June 17
- May 19, 2020
- April 6 & 13, 2020
- April 1 & 2, 2020
- SUNY Plattsburgh, Plattsburgh, New York, December 5, 2019
- Understanding New York State Tax Issues of 2019The Harvard Club 35 W. 44th Street, New York, NY, June 12 - August 7, 2019
- New York, New York, October 18, 2018
- October 9, 2018
- September 18, 2018
- September 4, 2018
- July 9, 2018
- July 2, 2018
- The Harvard Club, 35 W. 44th Street, New York, NY, Summer 2015
- Canada/U.S. Cross-Border Estate and Income Tax PlanningToronto, Ontario, September 17, 2014
- Hudson & Clifton Park, NY, June 4 & 5, 2014
- New York, NY, October 10, 2013
- Hamilton, ON, June 5, 2013
- Buffalo, NY, May 16, 2013
- Montreal, QC, March 14, 2013
- Toronto, ON, January 31, 2013
- New York, NY, January 16, 2013
- Calgary, AB, November 13, 2012
- Toronto, ON, May 10, 2012
- Calgary, AB, October 18, 2011
- June & July 2011
- Toronto, ON, November 18, 2010
- Calgary, AB, October 28, 2010
- Toronto, ON, October 29, 2009
- New York, NY, October 27, 2009
- June & July 2009
- Buffalo, NY, April 10, 2009
- Toronto, ON, March 25, 2009