Activity Areas

Tax Law Consulting in general, consulting about fiscal aspects regarding company reorganization and acquisition, structuring of tax planning in national and international operations, issue of professional opinions with respect to specific tax matters in diverse economic sectors, such as petroleum and gas, infrastructure, shipbuilding, concessions, energy, project finance, the financial market and the real estate market, among other activities.

Litigation of an administrative nature representing clients in suits involving federal, state and municipal organs of public finance, contestation of notices of infraction and terms of passive subjection, issue of appeals, requests for review of debts owed to the Union and other public entities, tax consulting processes, including presentation of briefs and oral arguments, in the second instance, especially in the Tribunal de Impostos e Taxas - TIT-SP (Tax Court), the Conselho de Contribuintes do Estado do Rio de Janeiro – CCERJ (Rio de Janeiro State Taxpayer Board) and the Conselho Administrativo de Recursos Fiscais – CARF (Administrative Council of Fiscal Appeals), among other activities.

Litigation of a judicial nature representing clients in cases involving Judiciary Power organs, including presentation of briefs and oral arguments in regional federal courts and higher courts in legal action discussion of the juridical-tax relation and rebate of balances charged unduly, annulments of tax credit, consignment in payment, security orders, fiscal execution, among other activities.

Consulting and litigation in issues related to the structuring and development of Foreign Trade operations, both importation and exportation, identification, enablement and operation of special regimes and specific controls suitable for the operations practiced by companies, such as Temporary Admission, Temporary Exportation, Customs in Transit, Drawback, Customs Warehouse, Recof, Repetro, Repex, Reporto, Customs Deposit Certificate, fiscal classification of merchandise, Customs valuation, representation of enterprises in specific verification procedures of the IN/RFB 228/02 (regarding identification of funds used in foreign trade transactions and combat of fraud in these), and in special control procedures of the IN/RFB 1169/11 (concerning suspicion of passive irregularities subject to the penalty of confiscation), among other activities.

Drafting of legal opinions and litigation in matters related to: accusation of the practice of fraudulent conduct, tax evasion and collusion (articles 71, 72 and 73 of Law no. N.502/1964); issue by the tax authorities of fiscal representation for criminal case purposes (Administrative Ruling RFB no. 2.439/2010); accusation of committing tax crimes (Law no. 8.137/1990), among other activities.

Legal consulting on the structuring and development of business activities, drafting and analysis of various types of legal documents, such as statutes and articles of incorporation, minutes of meetings, shareholder agreements, memorandums of understanding, asset purchase and sale contracts, as well as commercial accords in general. Client representation in court proceedings and in arbitration procedures.