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Tax Team Leader of Tax Team
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Taxes have a significant impact on a business and individuals. We have years of experience advising clients on tax matters including planning options available to them. Our expertise, experience and creativity enable us to provide cost efficient solutions emphasizing a proactive approach and timely and understandable communications. We endeavor to understand our client’s situation and seek practical solutions that are the best fit for the client.
Our tax team is composed of business attorneys with specialized training or deep experience in tax matters. Some also have accounting and financial backgrounds. Even though our tax team may be called upon by real estate, business and estate planning lawyers within the firm to assist them with the tax aspects of particular transactions or plans, our team often handles entire business transactions, not just the tax aspects of a transaction. While we benefit from access to lawyers in other areas of specialized practice within the firm, our team’s well-rounded experiences enable us to efficiently find practical means that address our clients’ multi-faceted needs.
We act as counsel for clients in federal income, gift and estate taxes and state and local taxes, including advising them on techniques to defer recognition of income, obtain advantageous tax rates, qualify for special tax treatments, exemptions and credits. We regularly address the following:
Choice of Entity - Formations- After assisting our clients in selecting the most appropriate form within which to conduct business, we form corporations, partnerships, limited liability companies, joint ventures, non-profit charitable and trade associations and foundations and provide advice on the tax consequences of such formations and contributions to capital.
Consolidated/Controlled/Affiliated Groups- We advise clients involved in multiple activities on asset protection techniques including how to create multiple related entities where appropriate, and we provide advice as to the tax and liability consequences of consolidated, unitary, commonly controlled and affiliated service groups.
Compensating Employees and Executives- We design and document employee benefit and incentive programs such as stock option plans, qualified retirement plans and non qualified deferred compensation programs and advise our clients on the tax consequences of these arrangements, severance arrangements, worker classifications and employment taxes.
Mergers, Acquisitions and Sales of Businesses- We assist clients structuring, negotiating and documenting tax free business acquisitions, mergers, reorganizations, spin offs and joint ventures. We also assist with taxable purchases and sales of businesses (representing both sellers and purchasers). We routinely address issues such as the allocation of purchase price, amortization of intangibles, tax indemnification, installment sales, sales and use taxes and real estate transfer taxes.
Liquidity Events, Exit Strategies and Business Succession- We work with clients to develop, from a myriad of choices, buy sell agreements under which some form of liquidity is provided for the owners/investors while not adversely impacting the entity and other business succession issues are addressed.
Real Estate Transactions- We work closely with the real estate practice group in structuring like kind property exchanges, sales and leasebacks, conservation easements, and structuring sales to minimize the rate of taxes, defer the payment of taxes and take advantage of various exemptions, credits and other special programs.
State and Local Tax Planning and Representation- We provide creative planning to avoid or minimize state and local income, excise, property, sales and use, and business and occupation taxes in Oregon and outside of Oregon. We have experience dealing with nexus, allocation and apportionment, unitary filing, business and non business income classifications and other issues of multi state activities. Our attorneys work with clients who are entitled to exemptions, deferrals, incentives or special assessments, advising them of those special benefit, the qualification rules and assist them in obtaining them. In addition to assisting clients in tax planning, we represent clients in audits, administrative appeals and litigation.
Individual Tax Planning- We advise clients on state of residence issues, methods to minimize state taxation as a potential sale of assets is being considered and the potential tax consequences of settlements of disputed claims. We offer independent objective analysis of tax “products” promoted by others as well as review proposed tax return positions.
Rulings and Audits- For proposed transactions involving significant unresolved tax issues, we have obtained advance rulings from the national office of the IRS. We also negotiate with the IRS and state tax authorities over issues raised on audit and represent our clients in administrative proceedings and litigation regarding taxes.
Non Profit Organizations- We represent tax exempt organizations, including public charities, trade associations, and private foundations. We assist them in their organization and in obtaining and maintaining any applicable income tax exemption and property tax exemptions, avoiding or minimizing the effect of private foundation status, minimizing unrelated business income tax and negotiating with federal and state taxing authorities in connection with such matters.
Dunn Carney ENews Related to Tax Issues
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