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FDH’s Tax practice actively advises private investment funds, family offices and portfolio companies on a broad range of tax considerations. In counseling our clients, we utilize our tax expertise to focus on the economic implications of tax planning and risk mitigation, helping clients to understand the practical business implications of tax structure, tax asset maximization and tax risks.

Our tax attorneys are influential in the M&A area, having written and presented extensively on complex structuring issues. Their extensive knowledge benefits our clients from the earliest possible stages of our engagement with attorneys across the firm.

We have particularly in-depth experience in the following types of matters, structuring M&A and growth equity transactions to maximize tax efficiency for both purchasers and sellers including:

  • Tax-deferred management rollovers.
  • Basis step-ups and NOL preservation.
  • Qualified small business stock qualification and maximization.
  • Cross-border transactional planning.
  • Structuring private investment funds.
  • Structuring and implementing equity compensation arrangements.
  • Structuring arrangements among principals of fund sponsors.
  • Advising funds and fund sponsors on partnership allocations.
We also offer representation in federal and state tax controversies.


Michael Spiro Quoted in Bloomberg Article on Connecticut Pass-Through Entity Tax

Michael Spiro was quoted in a recent article in Bloomberg exploring possible benefits for private investment fund managers of the new Connecticut Applicable Business Entity Tax. The article can be found here (subscription required). Read more

Michael Spiro Authors “Liability Shifts in Leveraged Partnership Freezes” in June 20, 2022 Issue of Tax Notes

The article explores ambiguities and traps for the unwary that are introduced in leveraged partnership freezes, and is available upon request. Read more

Michael Spiro Presents on Build Back Better Act Cross-Border Tax Proposals at NYSSCPA Taxation of Financial Instruments Conference

On January 11, 2022, Michael Spiro presented on proposed changes to US cross-border taxation at the annual Taxation of Financial Instruments Conference of the New York State Society of CPAs. Read more