There is an old joke that a camel is a horse that has been
designed by a committee. We all know that it isn't true. In
fact, camels are horses that have been bred for maximum tax
efficiency. Tax efficiency is the benign term that we use for the
tortured process of restructuring a business arrangement to
minimize taxes—all taxes, including income, sales, estate,
gross receipts, federal, state, city and foreign. When you realize
how many taxes there are and how many jurisdictions impose them,
the camel design looks pretty sleek.
Throughout my career as a business lawyer, without exception,
the most demanding call upon my skills has been to maintain the
structure of a business arrangement while striving for the greatest
tax efficiency. I have been privileged to do this in partnership
with highly skilled tax attorneys. There have been other
challenges, however.
