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Strategy

Entity Structuring

For formations, restructures, and ownership changes where legal form, tax treatment, and future flexibility all matter.

The problem

Legal form, tax treatment, and future flexibility are decided together or they are decided badly. Entity Structuring addresses the moments — formations, restructures, and ownership changes — where the structure chosen now constrains every option available later.

Who it’s for

Built for a specific kind of decision.

  • Operating companies forming, restructuring, or changing ownership
  • Business owners aligning legal form with tax treatment and long-term flexibility
  • Companies preparing the entity map for a future transaction or capital event

Scope of work

What the engagement covers.

Entity selection

Choice of legal form evaluated for tax treatment, governance, and the flexibility a future event will demand.

Restructuring scenarios

Analysis of restructure paths and their tax consequences before a reorganization is committed.

Ownership alignment

Ownership and equity arrangements structured so interests, control, and tax outcomes stay coherent.

Transaction readiness

Structure built so a future sale, recapitalization, or transfer is not constrained by a form chosen for convenience.

How Fortress works

One method, applied to this work.

The Fortress Hold Method is our way of turning complex tax facts into durable positions — a deliberate, five-step sequence built to hold under audit, professional review, and time.

Entity work is treated as load-bearing: the structure is designed to be internally consistent and sound across multiple years, not optimized for a single filing.

  1. 01Define the facts
  2. 02Evaluate exposure
  3. 03Build the structure
  4. 04Coordinate execution
  5. 05Monitor change over time

Related insights

Tax Alert

2026 · 8 min

Notice 2026-40: Two Opportunity Zone Regimes, One Hard Deadline

IRS Notice 2026-40, issued in June 2026, is the first transitional guidance on the Qualified Opportunity Zone program after the One Big Beautiful Bill Act (Public Law 119-21, § 70421) rebuilt it. The notice draws a hard line at December 31, 2026: investments made on or before that date stay on the original rules and face a mandatory deferred-gain inclusion in the taxable year that includes that date, while investments made on or after January 1, 2027 move onto a new permanent regime with a rolling five-year inclusion, a 10 percent basis step-up (30 percent for qualified rural opportunity funds), a fresh designation period running January 1, 2027 through December 31, 2036, and a 30-year ceiling on the gain-exclusion election. Two narrow safe harbors let previously designated zones keep functioning through December 31, 2047. Proposed regulations are forthcoming.

Read insight

Related industries

Sector environments where this work most often changes the answer.

All industries

Start here

Start with the situation, not the entity structuring brochure.

We begin by defining the facts and the timeline before recommending scope. If entity structuring is the right fit, we will say so — and if it is not, we will say that too.

Speak with a Fortress advisorAll services

A licensed CPA firm with CPAs on staff. Typical first response within one business day.