Tax planning involves the everyday implementation of strategies designed to maximize the ability to conduct business in a tax efficient manner, while complying with the letter and spirit of the tax laws. Whether planning for one or a series of transactions, or an event such as the sale or purchase of a business or significant asset, the effectiveness of tax planning considerations that respect legal and market realities can often be measured in terms of increased net returns.
Like businesses, high net worth investors require tax planning and face the daunting task of striking a balance between maintaining control over assets, while incorporating those assets into an overall plan of dispositional events designed to minimize gift and estate taxes, as well as income related taxes.
The attorneys in the firm have succesfully restructured business acquisitions and dispositions, mergers, executive compensation packages, and other significant business events, resulting in major improvements in the overall tax efficiency, and in many cases simplicity and manageability, of the transactions.
Tax controversy matters involve several stages of representation. Federal matters range from defending against positions asserted by the Internal Revenue Service, to audit representation, litigation in the United States Tax Court, prosecuting suits for refunds in the federal district courts, representing clients on appeal, in abatements, or suits for declaratory judgments and redeterminations of interest. When the IRS undertakes collection proceedings, representation involves taking appropriate administrative and legal steps to work to prevent seizures, levies, and help craft alternatives that absolve tax liability, or formulate and implement strategies to deal with existing liabilities within the law. At the state level, contoversy representation involves representation in relation to sales tax, franchise tax, and other state and local taxes imposed on businesses.
Sometimes a state seeks to collect taxes from out of state companies who have limited contact with that state. In such instances, federal statutes, constitutional due process and Commerce Clause considerations may limit the state's ability to impose taxes on foreign companies. In both state and federal proceedings, successful controversy representation involves thorough research and knowledge of the client's business, practices, and how the facts of each case dovetail into the many nuances of the tax laws.