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Tax

Domestic and foreign tax laws are the concern of every business — and business owner. Our Tax group helps clients develop effective tax strategies, address compliance and reporting requirements, and resolve tax controversies.

Global Overview

Enterprises of every size have operations, subsidiaries, and vendor and customer relationships that extend far beyond their jurisdictions. The same is true for institutional and individual investors. In today’s global business environment, compliance with international, national and local tax regimes has become increasingly important — and increasingly complex.

Ally Law member firms and lawyers have extensive experience advising clients in all aspects of tax strategy, compliance and tax dispute resolution. For companies seeking to develop or expand opportunities abroad, we offer tax planning that integrates foreign operations with their core domestic businesses. We assist clients in forming tax-efficient group structures in the various jurisdictions and advise on foreign commerce, tax incentives and trade grants, among other issues. At the local level, the presence of our member firms in markets worldwide enables us to better address our clients’ specific tax needs in their home countries and states.

The Ally Law Advantage

Ally Law includes member firms with solid credentials and significant experience in domestic and international tax law. We offer clients sophisticated, coordinated tax counsel virtually everywhere their operations, vendors and customers are found. We work cooperatively — with clients and our Ally Law colleagues — to deliver high-quality responsive service at competitive, local rates, and have a long history establishing strong, enduring relationships and effective tax strategies that strategic and tactical goals.

Our CLients

We represent regional, national and multinational, publicly traded corporations, privately and closely held companies, investor groups, and high-net-worth individuals who need coordinated legal strategies that can help them minimize their overall tax burden while maximizing financial returns.

Leaders

Ramona Azzopardi
Partner
WH Partners
Malta

Resources

Tax Benefits in France

Alerion describes why conducting R&D projects locally can be beneficial.

Tax and NFT's

WH Partners advises on whether foreigners who relocate to Malta then sell an NFT must pay taxes.

Taxation in an Event Regime Webinar

Head of Tax at Edwin Coe, Sean Bannister, discusses offshore bonds, foreign policies, and the chargeable event regime.

State and Local Tax in Ohio

Hear from Vorys tax professionals about the operative state and local taxes (direct and indirect) and related compliance considerations.

Ohio SALT Chronicle

Vorys State and Local Tax group provides updates on Ohio sales and use tax, tax exemptions for facilities, and more.

News

Tax law, practice and jurisprudence are struggling to keep up with the rapidly evolving space of digital technology.
The UK’s tax regime available to non-domiciliaries (or “non-doms”) has been the subject of much scrutiny over the years, but it is now in ever sharper focus following the Labour conference at the end of 2023 where Rachel Reeves confirmed that non-doms tax status would be one of the party’s targeted tax changes.
In this Client Alert, we highlight key considerations public companies should keep in mind when preparing their upcoming annual reports on Form 10-K and proxy statements, including rule changes, recent guidance and reporting trends.
A recently published government bill plans to modify the Hungarian personal income tax law by abolishing significant tax advantages associated with Hungarian trusts in a short period of time.
On May 16, 2023, the Israeli Tax Authority issued guidance regarding the taxation of investments in companies through the Simple Agreement for Future Equity (SAFE), which was introduced as an alternative to traditional investments or convertible loans for early stage investments in startups.
On May 25, Ramona AzzopardiWH Partners (Malta), and Julien LebelAlerion (France) led members in a discussion of the tax implications and pitfalls of cross-border real estate investments.
When a couple divorces or separates, the transfer of the matrimonial home and other properties as between them may trigger a capital gains tax (“CGT”) liability.
Gary Lineker’s recent suspension by the BBC, for a tweet from his personal account said to breach the BBC’s impartiality rules.

Services

We advise clients in jurisdictions worldwide in the full range of corporate and personal tax matters, including:

State, Provincial and Local Tax Regimes
  • Compensation and shareholder arrangements
  • Corporate reorganizations
  • Real estate taxes
  • Value-added tax (VAT)
  • Health and welfare plans
  • Qualified and nonqualified retirement plans
  • Corporate reorganizations
  • Intellectual and real property
  • Tax-deferred/like-kind exchanges
  • Estate, gift and generation-skipping taxes
  • Cross-border partnerships, joint ventures, buyouts and trusts
  • Taxation, foreign exchange and customs compliance
  • Estate and succession planning and implementation
  • Foreign investments
  • Advice on application of transfer pricing rules, special tax regimes and international tax treaties
  • Due diligence related to corporate acquisitions, reorganizations, liquidations, restructurings, divestitures, corporate financings and business combinations
  • Succession planning
  • Stock exchange issues
  • Counseling of banks and financial service providers and structuring of financial service products
  • Advice on structuring and implementation of option and compensation programs for middle and senior management
  • Trusts and estates
  • Formation, operation and maintenance of tax-exempt status
  • Obtaining IRS determination letters and similar document and rulings from local and national authorities
  • Taxation of unrelated business taxable income
  • Fundraising and compliance requirements
  • Federal tax controversy and litigation, including tax-related disputes and appeals
  • Preparing voluntary disclosures, objecting to tax assessments and securing advance income tax rulings and technical interpretations related to income tax and commodity tax matters
  • Taxation, foreign exchange and customs negotiations

Rankings

The Chambers Global Guide ranks the top lawyers and law firms in over 200 jurisdictions across the world. Some member tax highlights from the latest guide include:

Cascione Advogados (Brazil) is ranked in Band 2, Highly Regarded in Brazil, for Tax: Litigation for their deep legal knowledge and innovation handling complex and sophisticated matters. Tax lawyer, Luca Priolli Salvoni, was ranked Band 6 in Tax: Litigation and Band 5 in Tax: Rio de Janerio, and is described as “professional with remarkable technical knowledge, fully accessible to customers, objective, agile and insightful, always bringing a broad and dynamic view.” Gabriel Alves de Oliveira Baccarini was named an Associate to Watch in Tax: Litigation Brazil and Rafael Vega was named as Up and Coming Tax: Rio de Janerio.

Artegea Gorziglia (Chile) partner Andrés Ossandón is named Up and Coming and one interviewee comments, “He possesses a great knowledge and has a judicious approach when proposing legal strategies and giving advice.”

The Chambers Asia Pacific Guide ranks the top lawyers and law firms across markets in Asia-Pacific. Some member tax highlights from the latest guide include:

Gruba Caganda Advincula Melo & de la Fuente (GRUBA LAW), Phillipines, was ranked Band 3 in Tax with a particular strength in contentious tax matters serving a mix of domestic and international clients. Senior partner Lily Gruba is named an Eminent Practitioner.

The Chambers USA Guide ranks the top lawyers and law firms across the USA. Here’s a tax highlight from the latest guide:

Vorys (Ohio and Texas) Tax practice is ranked Band 2, known for handling a range of complex tax matters, including federal tax, and SALT and economic development incentives-related issues. One interviwee comments: “The team always grasps complicated issues quickly.” Tax lawyer Dan Jaffe is admired among market observers as, “being good at breaking down tax laws to explain properly and easily what a certain tax code means.”

The Chambers Europe Guide ranks top lawyers and law firms across the European legal market. Our Malta member has one esteemed lawyer ranked in the latest guide.

WH Partners (Malta) tax lawyer Ramona Azzopardi is ranked Band 1 for her work on a broad range of tax law queries, including corporate tax and VAT regimes, as well as double taxation treaties.

Chambers High Net Worth covers private wealth management work and related specialisms in key jurisdictions around the world, from professional advisers to wealthy individuals and families in each market. Here are some member tax highlights from this guide:

  • Blum & Grob Attorneys at Law (Switzerland) has a Band 2 ranked lawyer, Natalie Peter, who handles complex estate, trust and foundation matters and leverages her years of experience as a tax law expert in the private client field. One source says, “She is very responsive, sensible and provides a very partner-led service.”
  • Edwin Coe, LLP is rated Band 4 in Private Wealth Law- London Firms. One interviewee stated, “They are extremely good at complex matters, with a great attention to detail,” and are “particularly good at understanding the business issues affecting private clients.” Practitioners of note include Alison Broadberry, rated Band 3, who focuses on matters relating to trusts, estate planning, tax and cross-border probate, and is described as “intelligent and has seemingly unmatched reserves of energy and drive for her clients.”
  • Varnum (Michigan), ranked in Band 2, advises on a range of wealth planning matters, including business succession, trusts and tax matters. One client commented, “They are collaborative and they are able to handle sophisticated projects.” Partner Thomas Kyros advises on a range of matters including tax matters. A source notes: “He is very attentive to clients’ needs, providing a superior level of client service.” Partner David Thoms advises on a range of wealth planning matters and is noted to be “extremely responsive, creative and experienced attorney.” Also mentioned was Linsey Gleason, who advises on trusts and tax matters, is described as “great with clients” and “practical.”
  • WH Partners (Malta) is ranked in Band 2 and is an expert in Maltese tax matters. Her work also includes advising private clients on residency and wealth structuring. The Private Wealth Group at the firm, which routinely handles tax matters, is rated in Band 3.
  • Vorys (Ohio/Texas) Private Wealth team, ranked in Band 1, handles estate planning, tax issues and all other aspects of wealth planning such as drafting wills and trusts for high-net-worth families. One market insider comments, “They are top-notch in all regards.” Tax partner David Swift, Band 2, advises in all areas of their estate planning and trust administration needs, with one client comments: “He has got more experience and wisdom than his age would tell.”
  • Fabian VanCott (Utah) lawyer David Sloan of Fabian VanCott focuses on sophisticated estate planning work, including gift tax and generation-skipping transfer tax issues, and is described as a “very talented guy.”
  • Smith Anderson (North Carolina) is rated Band 3 in Private Wealth. Walter R Rogers Jr, rated Band 1, handles trust and estates and tax matters “is a respected lawyer in North Carolina,” remarks a source.

The Legal 500 EMEA edition analyzes capabilities of law firms in 80 jurisdictions across Europe, Middle East and Africa. Member firms highlighted in tax in the most recent guide include:

  • Edwin Coe, LLP (England) is ranked Tier 2 in the area of Private Clients: Personal Tax, Trusts and Probate. One client comments, “They have a pragmatic understanding of tax risks and a good working relationship with counsel of all levels of call to whom they are not afraid to turn for complex or finely balanced matters.” Senior lawyer David Goepel is described as a “charming, erudite trusts and tax lawyer who has been around long enough not to be phased by anything. He is a pleasure to work with and rightly adored by his clients.”
  • KCG Partners Law Firm (Hungary), ranked Tier 2, focuses on implications of corporate transactions and restructuring, advising on strategic tax planning, investment-related tax issues, employee and executive compensation tax schemes, and transfer pricing. The team also has strong tax litigation capabilities. One client comments, “The tax team has excellent understanding not just of the tax technical aspects but the business implications, and they come up with practical solutions that can be implemented.”
  • Gitti + Partners (Italy), ranked Tier 6, advises on the tax aspects of M&A, private equity and real estate transactions, corporate reorganisations, debt restructuring, investment funds, and financings.

The Legal 500 Latin America edition analyzes capabilities of law firms in Mexico, Central America and South America. Member firms highlighted in areas of tax in the most recent guide include:

  • PPO Abogados (Bolivia), ranked in Tier 1, is highly regarded for its “technical rigor, global vision, and extensive knowledge of the international standard.” The broad practice acts in sophisticated tax matters, including international tax planning, specified tax advising according to industry, and the most complex tax due diligence issues in the market. One client comments, “The technical rigor, the global vision, the extensive knowledge of the international standard (which is not very common in Bolivia) are its main virtues. Their best qualities are, without a doubt, that they go beyond what is asked of them, they are creative, rigorous and very proactive.” Notable individual and practice head Pablo Ordoñez, leads on the range of matters, but is particularly noted in international commodities, oil and gas, and litigation.
  • Cascione Pulino and Boulos (Brazil) is ranked in Tier 4 for Tax Advisory.
  • Artegea Gorziglia (Chile) is ranked in Tier 4, is known or its “thorough knowledge of the tax regulations” and broad experience in tax law, tax planning, the design of tax strategies, defending taxpayers’ legitimate activities, and the resolution of tax disputes; its track record includes advising on the tax aspects of company sale transactions, corporate reorganisations and financings. One client commented, “ the group has the ability to resolve issues, propose alternatives, and recommend paths to follow.”
  • Robalino (Ecuador), is ranked Tier 1, has “deep knowledge” and the “ability to analyse complex tax issues” across the planning, controversy and transfer pricing segments, as well as general tax advisory. Notable lawyer and practice head, Paola Gachet has deep experience wtih cross-border transactions as well as interactions with the tax authorities. One client states the team is, “Aware of clients, prepared to face the legal needs of the company, excellent knowledge and resourcefulness, good service.”

The Legal 500 Asia Pacific provides unbiased commentary and insight into the legal marketplaces of 25 Asia Pacific jurisdictions.

Boase, Cohen and Collins (Hong Kong) is praised for its services in Private Client (Tax, Trusts, Wealth Management and Contentious Probate) One source comments, “Boase Cohen & Collins is well equipped to handle a range of matters related to wills, succession planning, probate, estate administration and family law issues. Colin Cohen is the key name to note.”

ITR’s World Tax ranks effective tax practitioners around the world spanning more than 140 jurisdictions. Member firms highlighted in the most recent guide include:

Robalino (Ecuador) is classified as Tier 1 in Tax and Active in Transfer Pricing. Managing Partner, Javier Robalino Orellana is Highly Regarded in General Tax and Tax Controversy and Directors Bolívar Figueroa Martinez and Gabriel Gallegos are Highly Regarded for Tax Controversy.

PPO Abogados (Bolivia) is ranked as Tier 1 in Tax and Active in Transfer Pricing. Pablo Ordonez is Highly Regarded in Indirect Tax and Tax Controversy, while Alexandra Ortiz is a Rising Star in General Corporate Tax.

Artega Gorziglia (Chile) is ranked in Tier 2 for General Corporate Tax. Andres Ossandon is Highly Regarded in General Corporate Tax and Indirect Tax.

Santiavanez Abogados (Peru) is ranked Tier 4 in General Corporate Tax.

Gruba Caganda Advincula Melo & de la Fuente (Phillipines) is ranked Tier 2 in General Corporate Tax and Tier 1 in Tax Controversy. Angelo Vincula and Antero Caganda are both Highly Regarded in Tax Controversy.

Gitti & Partners (Italy) is ranked Tier 5 in General Corporate Tax. Diego DeFrancesco is a Notable Practitioner while Andrea Tognon is a Rising Star.