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Services

OUR APPROACH

Discovery: We partner with clients of all sizes and stages to understand your business and distill your tax objectives and challenges. We do this by speaking often with key stakeholders, gathering information, and analyzing your marketplace and tax landscape. We synthesize this into a factor driven framework to which we apply the tax laws and appropriate interpretations.

Strategy: Using the information from discovery, we outline the issues, applicable law, and conclusions using a reasoned analysis. We methodically address complexity breaking it down to critical elements.

Execution: We deliver our agreed upon product in a format that is workable and understandable to you, addressing our defined scope of services.

Security: 704beantown advisers, LLC has implemented a long-term security strategy and strong security program in line with industry best practices to protect client information and ensure network security.

TAX STRUCTURING AND MODELING

We work closely with management and legal counsel as deals come up throughout the year. We advise on and model tax implications of structuring domestic and international transactions, including new investments, ventures and global market expansion, dispositions and other deals in a tax optimal manner tailored to each client. We work with you from the negotiation phase through step plan implementation. We offer sophisticated tax structures and solutions to enhance exit value and reduce tax costs for all stakeholders. We identify opportunities for tax efficiency through ownership planning, repatriation and treaty eligibility planning, strategies for minimizing income and withholding taxes, utilizing tax attributes, reducing tax costs of anti-deferral legislation, and structuring foreign investment into US market opportunities. We advise regarding partnership allocations, distributions and capital account maintenance.

INTERNATIONAL PARTNERSHIP PLANNING

We advise partnerships regarding their US trade or business activity and implications to foreign partners regarding ECI, branch profits tax, and blocker alternatives. We advise regarding both inbound investment, as well as outbound partnership transactions, including CFC inclusions, IRC Section 1248 dispositions and PFIC planning.

SPECIALIZED PARTNERSHIP TAX CONSULTING

We have extensive experience working with clients that employ partnership structures and as a result have developed a deep expertise in the Subchapter K tax regulations. We can prepare analysis related to IRC Section 754 basis adjustments | IRC Section 704(c) allocations | IRC Section 736(a) and (b) payments | IRC Section 752 classification and Allocation of liabilities | Determination of Minimum Gain.

TAX CONSULTING

We can identify and advise on complex foreign or domestic tax issues, conducting research and analysis to scale and work with you to find solutions proactively.

ONGOING DILIGENCE READINESS

We help clients evaluate, assess, mitigate, and cure potential tax liabilities and historical exposure including domestic federal and state income tax, sales and use and international risk factors, such as permanent establishment, transfer pricing, reporting and tax withholding issues before it becomes a diligence issue.

TAX REPORTING AND COMPLIANCE REVIEW

We can assist with all aspects of partnership tax reporting, including reviewing annual compliance, international returns and transaction specific reporting. We can prepare internal work-papers maintaining IRC 704(b) and tax basis financials and capital accounts and allocation waterfalls.

“PARTNERSHIP REPRESENTATIVE” SERVICES

We can be named as your Partnership Representative and deal directly with the IRS on behalf of partnership, in the event of an IRS proceeding, as the IRS’ sole contact and as directed by the partnership.

TAX DISTRIBUTION STRUCTURING, CALCULATION AND ANALYSIS

We can assist you with understanding complex language in your legal agreements regarding the amount and timing of your tax distributions whether at the fund or portfolio company level. Often times the “Net Income” used for tax distributions is determined based on parallel tax accounting that can include and / or exclude items that are typically common to calculating normal federal tax income. We can help you navigate the many nuances that can come into play. We can also help you structure tax distributions at the portfolio company level.

FRACTIONAL “HEAD OF TAX”

In this capacity we would be wrapping all of these services (as needed) into a unique , more attentive and proactive tax advisor role as if we were on your internal management team.

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855 Boylston Street | Suite 10 | Boston MA 02116 | 857.263.5656