Jeffer Mangels Butler & Mitchell LLP has one of the leading tax practices in California, within a full service law firm. The Group's attorneys focus primarily on transactional matters. In addition to serving individuals, families, and closely-held businesses, our clients include organizations ranging from start-ups to Fortune 500 companies. When tax controversies arise, our clients rely on us to resolve the matter efficiently and effectively.
At JMBM, tax and business counseling blend seamlessly. Our tax lawyers understand business concerns, and work closely with colleagues in the firm’s corporate and real estate groups to ensure the tax efficiency of organizational and transactional decisions.
Tax consequences are often an extremely important component of many deals. We frequently play the lead role in negotiating and drafting transactional documents, partnership agreements, LLC operating agreements, shareholder agreements and buy-sell agreements. We also advise on the tax consequences of mergers, acquisitions and dispositions.
Choice of Entity
The choice of the appropriate entity for conducting a business is often made in light of the resulting tax consequences. We advise whether a business should operate as a partnership, limited liability company or corporation.
Ownership of real estate is a significant component of wealth for many of our clients. We advise them on the tax aspects of structuring the acquisition, holding and disposing real property, including choice of entity property tax reassessment, 1031 exchanges and special allocations and carried interests.
We assist clients in designing and implementing executive compensation programs such as nonqualified deferred compensation arrangements and stock options.
We provide international tax planning, typically in entertainment, real estate and technology ventures. We advise U.S. and foreign clients on ways to minimize taxes on income, the best structure in which to conduct international businesses, how to obtain U.S. tax credits for local taxes paid in a foreign jurisdiction and how to reduce or avoid U.S. federal and state withholding and employment taxes on income earned by foreigners providing personal services to U.S. entities.
State and Local Tax
We assist our clients with all state personal and corporate income tax issues, real property tax assessments, state sales and use taxes and employment taxes.
We frequently appear before the Internal Revenue Service, the Franchise Tax Board, the State Board of Equalization and the Employment Development Department in connection with audits of federal and state income taxes, state sales and use taxes, and employment taxes.
- For California State Automobile Association's San Francisco Headquarters: JMBM attorneys negotiate sale and leaseback SAN FRANCISCO – February 8, 2008—Jeffer, Mangels, Butler & Marmaro LLP (JMBM), one of California’s foremost full-service law firms, has announced that a team comprised of their Real Estate, Corporate, Finance, Tax and Land Use attorneys advised the California State Automobile Association (CSAA) in a complex sale and leaseback transaction that allowed for the sale [...]
- JMBM helps EZ Lube in recapitalization JMBM attorneys represented EZ Lube and its shareholders in its recent recapitalization – which included a sale of a significant portion of the EZ Lube’s owners’ equity position to an affiliate of Bruckmann, Rosser, Sherrill & Co, a New York-based buyout firm, plus a $105 million refinancing of EZ Lube with GSO Capital Partners and [...]
- Getting Results - A big tax controversy win In U.S. Tax Court and in the Ninth Circuit Court of Appeals, JMBM successfully represented against the IRS the two California founders of a women’s apparel business. The IRS attempted to disallow our clients’ deduction of business losses from their charter jet operation, saying that the business was not being run with the intent of [...]
- Getting Results - A transaction with sophisticated tax issues JMBM tax lawyers played a key role as members of our lead counsel team for client Frederick’s of Hollywood in its merger with Movie Star Inc. The complex transaction involved significant tax issues related to a $20 million rights offering and a one-for-two reverse stock split, and we structured the tax and financial terms to [...]