State, Local & Federal Tax

Advised Power Solutions, a leading Mid-Atlantic electrical contractor focused on data center construction, in its $2 billion sale to Dycom Industries, Inc. (NYSE: DY), a publicly traded national provider of specialty contracting services for digital infrastructure. Working on an accelerated timeline, the firm led a fully integrated, multidisciplinary team that guided Power Solutions through all aspects of the transaction, including M&A, tax structuring, financing, employment matters, and regulatory filings, helping the company achieve a landmark exit in a highly competitive and rapidly evolving market. The transaction strengthened Dycom’s data center platform by combining its fiber expertise with Power Solutions’ established leadership in electrical construction, reflecting Miles & Stockbridge’s deep experience advising clients on complex, high-value transactions in the data center and digital infrastructure space.  

To take advantage of the currently high federal estate tax exclusions, we had a married couple establish spousal lifetime access trusts (SLATs). Each spouse made gifts of assets up to their remaining estate tax exclusion amounts. The assets in the SLATs will be excluded from each spouse’s estates for State estate tax purposes because the State has no gift tax. The appreciation of the assets will be excluded from both spouse’s estates for federal estate tax purposes and if the federal estate tax exclusions go down, the clients will have made tax-free gifts of the difference between the federal estate tax exclusion when the gifts were made and the federal estate tax exclusion when the client dies. GST tax exemption were also allocated to each of the SLATs to allow the trusts to continue from one generation to the next without triggering a transfer tax. Because each spouse is a beneficiary of one of the SLATs, the gifted assets have not left the marital home.

Prior to joining Miles & Stockbridge, Meg advised licensed and chartered medical cannabis enterprise on various tax matters including the implementation of a corporate restructuring plan to mitigate the of impact of Code Section 280E, resulting in significant federal income tax savings.