Eagle River Professional Tax Services (“ERAKPROTAX”) is a boutique Alaskan tax law firm exclusively providing tax services. Proprietor Harry B. Carawan III has an advanced LL.M. degree in tax law and many years of experience in Alaska, North Carolina and Virginia representing corporations, partnerships, LLCs, individuals and trusts in connection with tax-sensitive transactions. Harry practices tax law in Alaska under his Virginia law license which he has held since 2004.
ERAKPROTAX takes an integrated tax and business approach that considers the goals both of companies and their shareholders. Harry counsels companies and their shareholders on pre-acquisition planning, where devices such as trusts and planned giving can be used.
Harry has worked with many of the largest CPA firms and companies in tax sensitive transactions and has served as a tax consultant to other law firms on tax matters. He has advised on tax aspects of mergers and acquisitions, litigation and settlement recoveries, international transactions, licensing and intellectual property matters and partnership tax issues. Harry’s tax representation experience ranges from individuals to closely held S corporations and limited liability companies (“LLCs”) to in-house tax departments of multi-billion dollar multinational corporations.
Pre-Acquisition Planning. Harry knows the acquisition process begins long before term sheet stage. His planning services include addressing tax matters before they become due diligence issues and result in delays or worse. Given his experience with corporate clients, Harry can anticipate and address a potential target’s problems prior to engaging with an acquirer.
A Holistic Shareholder-Corporate Solution. Unlike the approach of many law firms, ERAKPROTAX views the ultimate owners as constituents whose interests should always be considered. Harry will, if requested, provide advice to ensure a tax-efficient result to the stakeholders. ERAKPROTAX can serve as independent tax counsel to large shareholders in a transaction to ensure their tax concerns receive adequate consideration.
M&A Support. Due to his substantial tax expertise, Harry can assist other law firms on specific tax issues arising in large complex transactions. While Harry advises on general tax structuring, he also consults on specific items including the availability of net operating losses to an acquirer, issues peculiar to S corporations and LLCs. ERAKPROTAX advises on mergers and acquisitions in the following areas: tax-efficient structuring, such as forward and reverse subsidiary (triangular) mergers, tax-free reorganizations, Section 338(h)(10) elections and related matters; negotiating the tax provisions of transactional agreements; tax and legal due diligence for acquirers; and post-acquisition matters.
Partnerships and Limited Liability Companies (LLCs). The tax sections of a partnership or LLC agreement tend to be its most complex and economically significant provisions. Part of Harry’s practice has focused on negotiation and drafting of LLC and partnership agreements, including tax and distribution provisions. ERAKPROTAX can also provide modeling to test various allocations.
Cross-border Transactions. Business is of course international. At ERAKPROTAX, middle market clients may look to world markets for products and services, and may be characterized by U.S. management, European distribution, overseas manufacturing and development. Harry has extensive experience providing US inbound and outbound planning for multi-nationals, including the preparation of intercompany agreements, advice and analyses of transfer pricing policies, and permanent establishment and treaty issues.
Real Estate Tax. The real estate industry is tax-sensitive industry due to tax incentives granted real estate, as well as limitations to restrict perceived abuses prevalent in passive investment structures. Harry is able to team with seasoned real estate counsel to advise on tax and legal aspects of real estate transactions. Harry has experience in 1031 exchanges.
Business Succession and Estate Tax Planning. No tax practice is complete without an appreciation for wealth transfer issues. In conjunction with his business focus, Harry helps business owners and high net worth individuals plan for the orderly and tax-efficient transfer of their assets to their successors and beneficiaries.
Tax Practice and Controversy. ERAKPROTAX’s practice includes advice on federal and state taxation of transactions, including return positions planning and analysis, as well as representation of clients in connection with administrative hearings. In addition, Harry is licensed to appear before the U.S. Tax Court for litigated tax disputes. Harry represents taxpayers not only before the IRS audit and appeals divisions, but also before state departments of revenue including the Alaska Department of Revenue.