In our experience, we have found the initial phase of any engagement often to be the most important. Our first step in any business transaction is to gain a deep understanding of a client’s existing situation and business objectives so that we can not only fashion a solution that is responsive to the exigencies of the situation and meets accounting, regulatory and other constraints but, equally importantly, develop a strategy for achieving that solution.Developing a methodology based on careful research, long experience and creative analysis allows us to find solutions that might otherwise be less apparent. We pride ourselves on our financial analytical abilities that are essential in understanding each client’s situation. Many of our clients prefer that our role not stop until we have ensured that the plan that has been developed has been carefully and meticulously implemented in the matter intended. Documents must be consistent and precise. Solutions may involve operating constraints that need to be monitored. Internal financial staff may require assistance in properly reflecting a transaction on the clients’ books and relevant tax returns. Our approach is to be proactive; our objective is to ensure that the solutions are properly implemented.
In matters relating to tax controversies, there is no substitute for a very careful and exhaustive review of the facts and the essential elements of the legal principles that bear on the controversy. We start by understanding all of the essential facts and their financial implications at an extremely fine level of granularity, as we have found that the key to resolving such matters successfully often hinges on the smallest of details. Our approach often leads to agreement with the relevant taxing authorities on many of the facts, making any remaining controversy much more limited in scope. The legal issues and their context, of course, must be understood to a degree that enables one to craft persuasive arguments based on the legal precedents that could be brought to bear on the issues. In this regard, the breadth of our expertise offers us the opportunity to find the appropriate analogies when direct precedent may not be available. Our successes speak to the benefits our clients have enjoyed as a result of our approach.