A proactive approach to business tax rooted in financial experience
Dunn Carney’s Tax Team comprises attorneys with specialized training and experience in tax matters, including professional experience as accountants and financial planners. We use a proactive approach and timely, understandable communication to advise clients on tax matters and tax planning options, as well as entire business transactions, to best help clients achieve their goals.
Our tax attorneys act as counsel for clients in federal income, gift and estate taxes and state and local taxes, including advising clients on techniques to defer recognition of income, obtain advantageous tax rates, qualify for special tax treatments, exemptions and credits.
Our Tax Expertise
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.
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.
We design and document employee benefit and incentive programs such as stock option plans, qualified retirement plans (such as 401(k) plans and ESOPs) and non-qualified deferred compensation programs, as well as work with clients to correct operational errors. We advise our clients on the tax consequences of these arrangements, severance arrangements, worker classifications and employment taxes as well as HIPPA, COBRA, and ACA compliance and excise tax penalties.
We assist clients in 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.
We work with clients to develop, from a myriad of choices, business succession phases, and buy-sell agreements under which some form of liquidity is provided for the owners/investors while not adversely impacting the entity.
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.
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 benefits and the qualification rules, and assist them in obtaining the benefits. In addition to assisting clients in tax planning, we represent clients in audits, administrative appeals and litigation.
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.
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.
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.