Our tax practice has a broad and diverse client base ranging from individuals and small closely held businesses to Fortune 500 companies. Because of the breadth of our client base and the size of our tax practice, there are few, if any, tax areas not explored in detail by our lawyers. Tax lawyers bring their many years of experience to all aspects of federal, state, local and foreign tax matters. The group works closely with the firm’s substantial and diverse domestic and international business transactions practice and provides a full range of tax advice. Furthermore, because of the broad range of issues which give rise to tax controversies, the group has close working relationships with all of the firm’s Client Service Groups.

Members of the group represent clients in civil and criminal tax proceedings before federal, state, local and foreign tax authorities, administrative tribunals and courts involving a spectrum of income, estate, gift, excise, franchise, property, license, sales, use and value added taxes. This requires that group members have knowledge not only with the tax administration operations of clients, but also of the transactions and operations which give rise to tax issues. By doing so, we are able to determine the appropriate level for resolution of actual and potential issues, including legislative, agency or judicial relief.

Tax Advice

Members of the group have tax advice experience in:

• Federal and state tax planning in connection with the formation, acquisition, disposition, reorganization and liquidation of publicly and closely-held corporations, partnerships, and joint ventures;
• Practicing before the IRS National Office, the Treasury Department and Congressional taxwriting committees in connection with requests for advance rulings and technical advice, regulatory and tax legislative matters, and other Washington-oriented assignments;
• Federal and state tax planning for inbound and outbound transactions involving foreign taxpayers, intercompany transfer pricing, foreign currency transactions, and other international tax matters; and
• Preparation of tax-related opinions and disclosure materials in connection with corporate reorganizations, partnership syndications, stock and debt offerings, recapitalizations, tax-exempt financings, specialized investment vehicles (e.g., REITs, REMICs and RICs), and sophisticated real estate transactions.

Tax Controversy

The group has tax controversy experience in:

• International, federal, state and local tax advocacy at every administrative and judicial level;
• International, federal and state tax controversies arising out of the formation, acquisition, disposition, reorganization and liquidation of publicly and closely-held corporations, partnerships and joint ventures;
• Controversy as it relates to the creation, operation and dissolution of employee benefit qualified and non-qualified plans, welfare plans, health insurance continuation coverage under COBRA, executive compensation arrangements and multi-employer plan withdrawal liability;
• Advocacy before the IRS National Office, the Treasury Department and Congressional tax committees in connection with requests for advance rulings and technical advice, regulatory and tax legislative matters, and other Washington-oriented matters;
• International, federal and state tax controversies related to inbound and outbound transactions of foreign and domestic taxpayers, intercompany transfer pricing, foreign currency transactions and other international issues;
• International, federal and state tax controversies related to estate, gift and inheritance taxes;
• International, federal and state tax controversies in connection with corporate reorganizations, partnership syndications, stock and debt offerings, recapitalizations, tax-exempt financings, specialized investment vehicles ( e.g., REITs, REMICs and RICs), and sophisticated real estate transactions; and
• A broad range of federal and state tax controversies of colleges and universities, public charities, private foundations and other tax-exempt organizations.