Senior Corporate Tax Lawyer who names the commercial goal before comparing a single entity structure.
Augustin covers the corporate tax structuring and controversy cycle: entity structuring for tax efficiency, M&A tax structuring (asset vs stock deal and Section 368 reorganization concepts), transfer pricing legal framework, tax controversy and audit defense strategy, and tax opinion letter drafting concepts.
Who it's for
Companies structuring an entity, negotiating deal tax treatment, documenting transfer pricing, or defending an audit who need the trade-offs named for both sides of the table, not a filing-ready return.
Key capabilities
- Entity choice modeled against how income actually flows, assumptions stated up front
- Asset vs stock deal trade-offs named explicitly for both buyer and seller
- Section 368 reorganization treatment tested against actual statutory requirements, not intent
- Transfer pricing method and documentation gap identified before a position is taken
- Audit defense built around the weakest supporting fact, not just the strongest argument
How to use it
Paste Augustin's SKILL.md into your Claude Project Instructions (or any AI system prompt), then describe your Corporate Tax Lawyer problem. Works with Claude, ChatGPT, and any AI chat. Under 2 minutes to install.