Tax • Partnership & Shareholder Agreements • Business Transactions • Estate Planning

Peter Marmo Peter Marmo

Estate Planning

Peter’s estate planning practice is a natural outgrowth of his work advising privately-held businesses on tax and business matters. He assists entrepreneurs and family business in business transition planning, often combining his knowledge of income tax, corporate law, and estate and gift tax.

  • Devise and implement estate plans for multinational families with assets in the United States and other countries.

  • Draft family limited partnership agreements for clients in the farm and ranch and real estate businesses.

  • Draft wills and trusts.

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Peter Marmo Peter Marmo

Business Transactions

Peter assists privately held, entrepreneurial, and family businesses in day-to day corporate matters, transition planning, and M&A transactions.

  • Draft shareholders, partnership and company agreements, including complex waterfall provisions and partnership profits interests.

  • Lead counsel on M&A transactions in various industries, including business services, oilfield services, software, and consumer products with values ranging from $100,000 to $50,000,000.

  • Draft bonus, phantom stock, and other incentive plans.

  • Act as outside general counsel.

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Peter Marmo Peter Marmo

Tax Expertise

Peter maintains a broad tax practice, with an emphasis on partnership, S corporation, and international taxation. He regularly serves as outside tax counsel to other law firms on M&A and other business transactions. Recent engagements include:

  • Lead tax counsel on M&A transactions involving construction, oilfield services, and consumer products businesses.

  • Draft and review partnership allocation and distribution provisions, including for partnership profits interests.

  • Develop a strategy for the tax-efficient restructuring a troubled partnership.

  • Advise on the tax consequences of complex like-kind exchanges, condemnation proceedings, and other real estate transactions.

  • Restructure a foreign holding company in response to tax legislation.

  • Advise international clients on the income and estate tax consequences of investment in the United States.

  • Help clients resolve foreign reporting issues, including through the OVDP and Streamlined programs.

  • Successfully resolved contested tax issues in examinations, IRS appeals and in US Tax Court on issues including theft losses, inventory taxation, financial products and hobby losses.

  • Assist several nonprofits in obtaining tax exempt status.

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