CK Tax Services LLC – 2021: Year in Review

Despite the challenges of the pandemic and adapting to a new norm, 2021 was an exciting year for us! 

We have grown from 4 to 8 team members in less than four months by adding four passionate and eager professionals who embrace our firm culture of group collaboration and intensive learning.  Our new team members have been a great addition to our practice, as they strengthen the firm’s growth, in line with the firm’s vision to provide the best services to our clients.   

We take great pride in our ability to work closely with our clients, develop strong relationships, and be their strategic trusted advisors.  We look forward to continuing to grow our relationships with our clients and contacts in the year ahead by continuing our reputation for providing effective, dynamic, and holistic solutions.

We worked hard in 2021 to achieve our clients’ goals, some of our favorite achievements were: 

• Reduced a tax holdback on a $20 million deal from $3.5 million to $0 in the course of representing a technology target of an acquisition and leveraging the acquiror’s erroneous tax analysis to receive a single payment of the purchase price in 2021 instead of installment payments over a number of years;  
  
  
• Structured an acquisition to allow the Buyer an additional $4 million in depreciation/amortization deductions pursuant to their acquisition of a medical service company and guide them through a corporate restructuring to accommodate opportunity zone fund equity on a tax-free basis, bank financing, and an election to treat the stock purchase of the target as an asset purchase;  
  
  
• Structured a stock sale to reduce a key shareholder’s worldwide tax liability by more than $6 million on a $45 million purchase price for their shares pursuant to an acquisition of a foreign corporation;
   
  
• Executed pre-immigration planning to increase a client’s tax basis in closely held business stock from $0 to $40 million prior to commencement of U.S. tax residency without any U.S. or other country taxation thereby reducing gain by $40 million on an anticipated sale of the stock in 2022;  
  
  
• Represented individual clients to remove Forms 3520 and 3520-A related penalties erroneously imposed by the IRS; 
  
  
• Prepared the tax structure and related work for the formation of 3 private equity funds, each fund in excess of $100 million, including structuring for tax efficient investment for U.S. taxable persons, foreign persons, and tax-exempt entities;
  
  
• Prepared the tax structure for a crypto mining company including tax efficient acquisition of a power plant, offshore structuring of $50 million worth of equipment, and related tax implications for investors;
  
  
• Tax planning for  a nonfungible token (NFT) company that is looking for an exit through a special purpose acquisition company (“SPAC”);  
  
  
• Reviewed two recent acquisitions of a digital marketing firm and post-acquisition structured a change in how the acquisition occurred for tax purposes allowing for an increase of $5.3 million in the tax basis of the assets thereby allowing for tax savings in excess of $2 million; and  
  
  
• Structured a qualified opportunity zone fund investment to comply with the rules to allow for tax deferral of investors contributed capital gains, 10% reduction in tax base, tax free growth of the investment, a restructuring to coordinate the investment of two funds, and considerations for foreign investors.
  

2021 was indeed a huge year for us and we look forward to supporting your business and tax goals in 2022.