TAX PLANNING AND CONTROVERSY

Successful closely held business owners and high net worth individuals rely on our Tax Planning and Controversy Group for a variety of advisory and representative roles, including:

•  Individual tax planning
• Business and tax planning for Subchapter S corporations and partnerships
• Multistate tax planning
• Property tax and sales tax issues
• IRS appeals
• U.S. Tax Court representation.

We help entrepreneurial clients maximize tax benefits in the areas of multistate taxation, sales and use tax, local taxation and ad valorem property tax assessments.

The Tax Planning and Controversy Group assists corporate clients seeking private letter rulings from the National Office of the Internal Revenue Service and state departments of revenue. We also vigorously represent corporate and individual taxpayers in controversies with the IRS, state departments of revenue and local taxing authorities.

Our tax advocacy and representation spans all levels, including tax audits, administrative appeals and litigation or trial of tax cases in various courts, including the United States Tax Court. Many tax cases are settled after a revenue agent’s examination or settlement conferences with the appropriate taxing authority.

If litigation is required, our significant professional resources and trial experience allow us to effectively prepare and try complex commercial tax cases. We also represent taxpayers of criminal tax investigations in selected types of cases.

The Tax Planning and Controversy Group provides international corporate and tax services, and has helped numerous clients establish operations abroad. We have assisted international clients with entity selection and formation, outbound international tax planning, royalty structuring, foreign tax credit planning, licensing and registration.

Our clients benefit from our international network of foreign legal firms. We have provided tax advice or formed new companies in Mexico, Argentina, Brazil, Australia, Germany, Poland, Czech Republic, Hungary, Turkey, Netherlands, United Kingdom, Canada, Korea and China.