Tax

Taxation

Our tax attorneys understand our job is to help you and your company keep the most of your hard-earned dollars. We represent high net worth families, entrepreneurs, and thriving companies that have built wealth and provide prosperity to their employees and value to their customers. We help you minimize your income, estate and gift taxes, so you have as much control as possible in deciding how to deploy your capital now and in the future.

We pride themselves on their approachability, thoughtful analysis, and ability to distill thoughtful solutions to complex problems into clear, plain language. We strive to provide the best and most tax-efficient strategy for each client and situation.

CJMH tax attorneys are thought leaders who regularly provide tax continuing education to accountants and attorneys through our tax breakfasts and annual tax seminar. We can stack up our tax credentials against much bigger firms: The department includes multiple AV-rated attorneys recognized as “preeminent” by their peers, Texas Board of Specialization certifications, Masters of Law in Taxation, as well as Certified Public Accountants.

We provide innovative and up-to-date tax solutions for all manner of sophisticated business transactions including mergers and acquisitions, real estate development, corporate reorganizations, and structuring domestic and international investments.

CJMH Tax Experience

Mergers & Acquisitions, Spin-offs and Joint Ventures: Advising our clients on the most tax-efficient transactional structures within a single jurisdiction or across multiple jurisdictions. Representing numerous publicly traded corporations in tax free spinoffs, as well as other complex restructurings
Tax Structuring, Restructuring and Insolvencies: Advising corporations, financial institutions, and financial sponsors on tax-efficient ways to structure both cross-border and domestic holdings and investments.
Representing debtors and creditors in complex restructurings, exchange offers, bankruptcy reorganizations and liquidations including creditors trusts, oil and gas companies. Also represented creditors in the two largest bank failures in Texas history, with all creditors being paid in full in both cases.
Equity Compensation: Designing and implementing equity and equity-like compensation plans
Private Wealth & Family Office: Advising high-net-worth individuals and families in all aspects of estate planning, estate and trust administration, multigenerational wealth transfer planning, income taxation, estate and gift taxation, the formation and administration of tax-exempt charitable entities, and tax-efficient operations of family offices.
Real Estate. Real estate investment trusts (REITS), master limited partnerships (MLPs), complex debt instruments, royalty trusts, and federal income tax matters related to inbound and outbound foreign transactions (e.g., FIRPTA)
Master Limited Partnerships. Representing issuers and underwriters in initial and subsequent public offerings of equity interests, as well as debt offerings in publicly traded partnerships (PTP’s; MLP’s). Representing underwriter in first MLP to corporation conversion
International Taxation: Identifying and implementing tax-planning strategies to minimize worldwide tax liabilities; planning and structuring in-bound or out-bound investments
Obtained first IRS Private Letter Ruling sanctioning use of high/low voting stock to satisfy control requirement
Negotiating complex joint venture, partnership, and limited liability company agreements, including those with profits interests, multiple classes of equity, preferred returns, convertible equity and debt interests, targeted allocation provisions, New Centralized Partnership Audit Regime (“NCPAR”) compliant allocation, distribution, and transfer restriction provisions.
Tax Credits. Negotiating and structuring tax credit transfer transactions and securing IRS favorable private letter rulings on credit eligibility and validity of transfer structure.