Christine M. (“Chrissy”) Green counsels clients on federal, international, and state tax issues pertaining to transactions, structuring, and compliance. Chrissy frequently assists clients in business transactions by providing tax structuring options such as tax-deferred rollover structures and guidance on the tax aspects of company acquisitions and disposal. She also advises clients on incentive compensation plans in relation to business transactions.
Counseling clients on numerous federal tax compliance difficulties relating to corporate and pass-through taxation, as well as other tax topics like section 280E application in the cannabis industry, worker classification disputes, and employee retention tax credit issues make up a sizable portion of her tax practice.
She counsels non-U.S. individuals and companies on the U.S. federal and state tax consequences of establishing and conducting business in the U.S. In connection with doing so, she counsels clients on the application of US tax treaties. She advises people and businesses from Canada, Europe, India, Mexico, and other geographies on choice-of-entity tax matters when launching a business in the United States.
Chrissy also handles concerns for nonprofit organizations, such as petitions for exempt status and state charity solicitation registration and filings, and represents clients with regard to state tax difficulties, such as state income and sales and use tax obligations.
• Represented the seller of a staffing business and advised on structuring the sale to achieve tax-deferred rollover treatment
• Represented business owners seeking to retire and advised on how to exit or sell in a tax-efficient manner
• Executed restructurings to allow for businesses taxed as S corporations to accept investments and engage in tax-efficient sales
• Advised businesses on how to navigate compliance issues related to the Corporate Transparency Act
• Provided reviews of employee retention tax credit claims and eligibility
• Advised acquirers on the tax-efficient structuring of business acquisitions including providing tax deferral opportunities for sellers
• Counseled non-US individuals and businesses on US tax issues with respect to forming a US entity and doing business in the US
• Advised businesses on a variety of tax compliance matters such as payroll tax issues for remote workers and non-US workers
• Negotiated the purchase price allocation to prevent the overpayment of taxes for a manufacturer in the sale of the entire business
• Successfully defended an equine business in an IRS worker classification audit and examination
• Advised a cannabis growing operation on formation and tax structuring issues to maximize potential tax deductions
• Represented a natural gas company in connection with offering investment opportunities in a drilling fund
• Advised a fund in the digital asset and cryptocurrency markets on US tax issues related to investments in digital assets and cryptocurrencies
• Advised a family business on alternatives for restructuring and limiting the tax impact of debt forgiveness income in connection with a debt workout
• Represented the seller of carbon dioxide emissions in connection with claiming the carbon oxide sequestration tax credit
• Advised a renewable energy producer on qualifying for various tax credits under the Inflation Reduction Act
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