Corporate Tax

Holland & Knight's Corporate Tax Team goes beyond advising on tax – we architect the structures behind your deals. Our team embeds with clients from Day 1 to design entity formations, restructurings, mergers and acquisitions (M&A), divestitures and tax-free reorganizations that are built to perform, legally sound, tax-efficient and aligned with your business.

From public offerings to private equity raises to high-stakes restructurings, our attorneys build tax-efficient capital strategies that create and protect enterprise value across every stage of the business life cycle.

We handle a variety of operational tax work – including consolidated returns, corporate reporting, IRS technical advice and private letter rulings – bringing extensive experience and knowledge that can provide our clients with a competitive advantage.

Overview

Holland & Knight's Corporate Tax Team isn't built around checklists – it's built around outcomes. Our attorneys sit at the intersection of tax law and business strategy, working shoulder-to-shoulder with clients to form, restructure and – when the moment calls for it – unwind business entities in ways that extract maximum tax efficiency from a challenging regulatory landscape.

Our lawyers bring deep, hands-on experience in the tax dimensions of mergers and acquisitions (M&A) and other corporate transactions, divestitures, leveraged buyouts and tax‑free reorganizations, designing structures that serve your deal today and your business strategy for years to come.

Representative Engagements

Led tax structuring for Azure Summit Technology's $1.275 billion sale of an engineering company that develops high-performance radio frequency hardware and software-defined technologies for national security applications, guiding the transaction through complex regulatory approvals
Advised on the tax and corporate structuring of the nearly $1.8 billion sale of a portfolio company to a leading global alternative asset manager, including ongoing counsel to the founder on approximately $250 million in personal transaction proceeds, asset protection planning, trust planning and establishment of a family office
Advised on the tax structuring of a $700 million acquisition of a healthcare practice by a private equity fund, including structuring substantial rollover equity for historic owners and continuing add-on acquisitions with additional rollovers
Provided tax counsel on the structuring of non-U.S. subsidiaries in connection with the $665 million sale of a multinational business providing financial services support with operations across the U.S., China and India
Advising on the tax structuring of a $350 million private equity investment into a closely held cloud computing and artificial intelligence (AI) technology service provider valued at $3.5 billion, optimizing federal, state and local tax treatment for the business and its founder and addressing cross-border implications of foreign branches and subsidiaries across the European Union, United Kingdom, South Korea, Japan, Australia, Brazil, Mexico and South Africa
Led the tax structuring for a $150 million cross-border domestication of a foreign-based software company into the U.S. in conjunction with a venture capital fund equity investment, achieving a tax-free restructuring for U.S. and foreign-based shareholders with operations spanning the British Virgin Islands, Argentina and Mexico

Representing a major international oil and gas company in an approximately $500 million federal income tax case involving significant partnership, production payment and penalty issues arising from a restructured joint venture with Qatar, securing a favorable district court ruling that the production payment constitutes debt for federal income tax purposes and rejecting the government's judicial doctrine arguments
Advised a major energy company on complex nonrecourse liability and deduction issues relating to a joint venture, determining the allocation of more than $1 billion in taxable income between the parties over multiple years in connection with multibillion-dollar production payment liabilities
Serving as lead litigation counsel for a major airline in a novel Texas franchise tax case involving federal preemption under the Anti-Head Tax Act, with more than $20 million at stake across multiple tax periods, following a favorable bench trial decision that is now on appeal

Advising insurers on more than $3 billion in tax insurance policies in connection with renewable energy tax credit transactions under the Inflation Reduction Act, analyzing deal structures under federal and state tax laws and crafting insurance policies to cover risks arising from tax equity partnerships and mergers and acquisitions transactions
Structured a $500 million securitization facility for a financial services fund, designing both domestic and foreign parallel fund structures with intensive analysis of U.S. trade or business issues faced by foreign investors
Provided U.S. tax, corporate and investment advisory services for a $2.5 billion multifund platform's formation of a new U.S. subsidiary, coordinating with foreign counsel across multiple Latin American and European jurisdictions on fund formation, U.S. Securities and Exchange Commission regulations, corporate governance and U.S. international tax issues
Handled all tax structuring for a $100 million investment in a renewable energy developer that owns, operates and invests in renewable energy projects throughout North America

Representing a family with $1 billion in assets held through entities in Hong Kong and the British Virgin Islands in restructuring into U.S. tax-efficient structures, including Section 962 planning, a potential Delaware corporation blocker leveraging the dividends received deduction, large-scale U.S. real estate restructuring and pre-immigration trust strategies
Advising a Canadian billionaire on U.S. tax considerations associated with a liquidity event valued at more than $1 billion, including trust planning, domestic and international corporate tax issues and the interplay between U.S. and Canadian tax regimes
Handling multijurisdictional trust, foundation and corporate restructuring involving more than $1 billion in assets across seven countries for a family responding to political instability, including coordinating U.S. federal income, gift and estate tax planning to ensure assets are efficiently transitioned and protected from unintended U.S. tax exposures
Consolidating and restructuring multiple trusts located in the U.S. and abroad with underlying U.S. and European real and personal property investments valued at more than $600 million, coordinating with tax, corporate and trust counsel across 10 jurisdictions following the unexpected death of the settlor
Providing tax and corporate advice for a major independent oil and gas producer in the Middle East on multi-country holding company and family limited partnership restructurings valued at approximately $450 million across seven jurisdictions
Serving as legal counsel for the corporate and tax structuring of a $270 million mixed-use Opportunity Zone development in Miami, designing the qualified opportunity fund structure, negotiating the development joint venture and preparing all investment offering documents, including structuring a $70 million nightclub project and a complex ground lease with the city of Miami