Avi is a tax attorney practicing in the Business Law Group, the Public Finance Group, and the Trusts and Estates Group. He assists clients with tax planning and transactional analysis at the federal, state, and international levels, and represents taxpayers in disputes with the Internal Revenue Service, Massachusetts Department of Revenue and other tax authorities.

Avi works with domestic businesses and multinational corporations to design tax-efficient structures for acquisitions, dispositions, reorganizations and mergers, including financial modeling of the after-tax consequences of such transactions. Avi designs partnerships to accommodate the specific tax situation of each partner. He also provides tax counsel in executive and employee compensation matters, and regarding the golden parachute excise. He also assists developers and non-profit agencies in securing capital financing through tax-free municipal bonds.

Empowering individuals to achieve their personal, business and financial goals while minimizing tax impediments is Avi’s primary role in tax and estate planning. Where appropriate, Avi also helps clients to take advantage of tax credits (for example, in alternative energy development). He assists with succession planning for closely held businesses to allow transfers to the next generation at nominal tax cost.

Avi’s state tax background includes addressing corporate excise, transfer and sales taxes, and compliance and reporting questions. He assists companies starting new businesses in, or relocating to, Massachusetts, addressing entity choice, registration, tax elections, and capitalization. Avi also assists individuals with domicile questions and change-in-residency planning. His audit defense experience includes addressing jurisdictional and “nexus” issues, “sham transaction” and “economic substance” cases, apportionment problems, and qualification for state and federal research and investment credits.

In his active tax controversy practice, Avi defends both businesses and individuals before the Massachusetts Appellate Tax Board and U.S. Tax Court, as well as in hearings before the IRS and the Massachusetts Department of Revenue. He also represents taxpayers regarding delinquent returns and handles tax collection cases, levies and liens. Avi regularly assists property owners with controlling property tax costs and addressing valuation issues.

Avi has been active in working for better tax policy and regulation. He has contributed to the development of the current Massachusetts apportionment regulations, and has provided testimony on proposed tax legislation on several occasions.

Avi has been an attorney since 1980. His prior experience includes working as a tax associate at Sullivan & Worcester and as a senior tax associate at PricewaterhouseCoopers. Avi writes and lectures frequently on tax topics, and has taught classes at Boston University School of Law (LL.M. Taxation program) and at Northeastern University (M.A. Taxation program).

• Secured large cash payouts for a group of executives when their employer-company was sold, by successfully avoiding a significant golden parachute excise.
• Prosecuted $12 million abatement claim for a Massachusetts intellectual property holding company.
• Developed a specialized partnership structure for real estate investments, in order to maximize depreciation and allocate tax losses to the high-income partner.
• Minimized tax impact on sale of business assets in a wide variety of stock and asset transactions.
• Addressed tax issues in connection with a publicly traded blank check company.
• Created modifications to a public company’s Incentive Compensation Plan, conforming to the complex new Section 409A regulations, while maintaining strong and workable incentives for employee performance.
• Structured several litigation settlements so at to minimize taxes paid, in employment discrimination and other cases.
• Facilitated several tax-free transactions:
• Arranged Section 1031 exchanges, allowing clients to sell gain property without current tax liability;
• Arranged for the tax-free conversation of a 122-unit apartment building from a housing cooperative to a condominium form of ownership;
• Helped a church maintain its tax-exempt status and property tax exemptions during the relocation of its main facility;
• Assisted a Buddhist association in the tax-free sale of its temple;
• Advised a nonprofit social club how to receive a large donation for capital improvements to its clubhouse, while avoiding any tax or loss of its tax-exempt status.
• Defended a technology business owner against allegations of an unlawful tax shelter.
• Represented the donor of a greenspace conservation easement in a valuation dispute with the IRS.
• Resolved a controversy over a restaurant’s tip reporting policy.
• Provided a tax opinion that a video production company’s product was exempt from California state sales tax, providing a competitive advantage to the company.
• Provided tax counsel and prepared tax opinions regarding impact of federal, state and local taxes (including income, excise, sales, and real estate transfer taxes) for acquisitions of national companies in several jurisdictions.
• Secured $2 million reduction in corporate income tax by creating offshore captive insurance companies.
• Advised U.S. software firm opening a Brazil sales office and determined methods for reduction of taxes on repatriated profits.
• Secured complete abatement (zero tax due) of local personal property tax for a Boston area shipyard in a controversial, widely reported case.
• Reduced sales and use tax obligations through reclassification and extrapolation.
• Negotiated favorable settlements of Massachusetts inheritance tax on unvested future interests.
• Prosecuted claim for abatement of excise tax based on the Massachusetts Research Credit.
• Counseled taxpayers in IRS collection procedures; prepared and negotiated offers in compromise.