practices
Experts in various fields find solutions for customers. We provide customized solutions based on a thoroughly analyzed litigation database.
Tax Laws
Where business strategy meets tax expertise.
At SJKP LLP, tax is more than compliance—it’s an opportunity. We help multinational companies transform tax complexity into strategic clarity. With deep technical skill and a commercial mindset, our attorneys and economists craft solutions that align with your vision, whether you’re launching in a new market or navigating a high-stakes audit. Our integrated approach ensures that tax planning strengthens both operational efficiency and competitive advantage.
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1. Tax structuring tailored to cross-border growth
Today’s tax landscape demands more than just local know-how. It requires a global lens, synchronized with local precision. We advise on structuring international operations, from holding companies and hybrid instruments to treaty-based planning and global supply chain alignment. Our goal is to make tax structures not only compliant but also resilient, giving businesses the agility to expand without unnecessary fiscal risk.
Tax strategy and risk mitigation
Abuse of transfer pricing is a flashpoint for scrutiny. We design policies that withstand audits and craft documentation that protects your global operations—grounded in OECD standards and local nuance. By aligning with best practices, we help clients avoid costly disputes and maintain transparency with regulators while optimizing their global tax position.
OECD Pillar Two and minimum tax readiness
We help businesses model effective tax rates, navigate the rules, and prepare for top-up tax implications. Our team ensures that companies remain compliant while minimizing disruption to their financial planning, enabling management to adapt to evolving international tax frameworks.
2. Tax controversy: from audit defense to litigation
When tax authorities call, we respond decisively. From federal and state audits to litigation before tax courts, our seasoned team guides you through each step—ensuring your rights, business continuity, and reputation are protected. We balance aggressive defense with strategic negotiation to achieve resolutions that preserve value.
Criminal tax defense and voluntary disclosures
Facing allegations of tax evasion or foreign account violations? We provide discreet, strategic counsel—resolving risk through effective disclosure or, if necessary, courtroom defense. Our attorneys help clients evaluate disclosure programs, negotiate with authorities, and prepare comprehensive defenses that protect both financial stability and personal reputation.
3. Tax in transactions: deal-driven advice
In every deal, tax tells the story beneath the numbers. We shape transactions—M&A, real estate, finance, and IP—with a sharp tax lens, identifying risks early and aligning outcomes with your commercial goals. Our proactive advice ensures that tax structuring enhances deal value rather than eroding it.
Post-deal tax integration
Beyond closing, we help you merge systems, unwind legacy structures, and manage inherited risks—because a good deal doesn’t end with a signature. We advise on harmonizing accounting policies, addressing hidden liabilities, and integrating tax reporting, creating a smoother transition for both companies and stakeholders.
R&D tax credits and innovation funding
Innovation thrives when it’s incentivized. We identify and secure tax credits that fuel your R&D investments across jurisdictions. From federal R&D credits in the U.S. to incentives in Europe and Asia, we help businesses capture benefits that support long-term growth while remaining fully compliant.
4. Tax Services: Sector-Focused and Globally Coordinated
We think beyond the box. Our tax professionals collaborate with SJKP LLP’s industry experts in corporate, IP, real estate, and more—delivering holistic, sector-specific tax solutions. This collaboration ensures that tax considerations are fully integrated into broader business strategies, maximizing efficiency and reducing risk.
Privilege protection in every engagement
We operate under attorney-client and work product privilege, ensuring every conversation and document remains protected—especially during disputes. This commitment allows clients to engage openly with us, confident that their sensitive strategies and disclosures are legally safeguarded.
5. Tax professionals navigate complex legal and regulatory frameworks
The tax environment is built on multiple overlapping regulatory systems. At SJKP LLP, we guide clients through these frameworks with clarity and precision.
We advise on the U.S. Internal Revenue Code (IRC), helping companies interpret and apply complex provisions across multiple sectors. Our team provides counsel on the OECD Transfer Pricing Guidelines, ensuring transfer pricing policies are robust and defensible.
We also assist with compliance under BEPS 2.0, including Pillar One and Pillar Two, where multinational groups must prepare for global minimum tax rules and shifting profit allocation standards.
Our lawyers support clients in meeting FATCA and CRS international reporting requirements, designing systems to track, collect, and disclose financial data across borders.
We provide guidance on U.S. State Tax Codes, which vary widely and often conflict with federal tax positions. In addition, we advise on IRS Notices and Revenue Procedures, interpreting evolving guidance to keep compliance systems up to date.
By addressing each layer of this regulatory ecosystem, we help clients maintain compliance while leveraging opportunities for efficiency and growth.
The information provided in this article is for general informational purposes only and does not constitute legal advice. Reading or relying on the contents of this article does not create an attorney-client relationship with our firm. For advice regarding your specific situation, please consult a qualified attorney licensed in your jurisdiction.
