William M. Funk, Esq.
Senior International Tax Counsel
William M. Funk is a tax attorney with extensive experience in tax planning and dispute work. His practice focuses on individuals, businesses, funds and non-profit organizations.
Prior to starting his law practice in 2009, he practiced tax law for ten years with firms in New York. He has successfully represented clients before federal and state tax authorities and in business negotiations.
Representative matters include:
Advising funds on structuring domestic, inbound and outbound investments, including issues such as entity election, drafting offering documents, tax treaty planning and compliance with withholding and reporting rules.
Advising non-U.S. businesses on structuring U.S. operations, including issues such as entity elections, acquisitions, tax treaty eligibility, planning and compliance with withholding and reporting rules.
Advising and representing corporations in mergers and acquisitions (both buy-side and sell-side), including issues such as net operating loss preservation, restricted equity considerations, golden parachutes, international considerations, and drafting of covenants, representations and warranties.
Advising real estate developers on 1031 (“like-kind”) exchanges, extracting refinancing proceeds on a tax-free basis, workouts of underwater properties, formation of partnerships and crafting allocations and distributions.
Organizing and obtaining tax exemptions for nonprofits including public charities and private foundations, advising nonprofits on all phases of their life-cycle, from formation to operations (including domestic and international) to dissolution.
Structuring investments and developments by nonprofits to avoid exposure to unrelated business income tax (UBIT).
Advising businesses on sales tax and other state and local taxes.
Representation of individuals and businesses before the Internal Revenue Service regarding worker classification disclosures and FBARs, FATCA and other foreign asset and income compliance.
Representation of individuals before the Internal Revenue Service and the New York State Department of Taxation and Finance in tax litigation and regarding relief from garnishment of wages and levies on bank accounts.