Most commercial transactions involve tax considerations. We routinely advise clients on how to minimize the state and federal tax liability associated with their business activities. In addition to providing advice on the tax implications of routine business operations, we counsel clients on tax strategies affecting buying or selling a business, and properly implement such strategies in the transactional documents. We also assist clients in evaluating tax compliance of target companies. Working with clients’ accounting and financial professionals, we strive to develop strategies that add value and help to bridge the gaps necessary to complete transactions.
Dealing with the IRS and state revenue agencies with respect to a tax liability dispute can be unsettling and disruptive. These taxing authorities have significant power to impose interest, assess penalties and file liens. Quick action to resolve any issues can help to avoid interest, penalties and other disruption to the business. We routinely negotiate with the IRS and departments of revenue on behalf of clients to reduce liability from unpaid taxes, penalties and interest, sometimes for a fraction of the amount owed.
Successful resolution of tax controversies often begins long before reaching an IRS or state appeals officer. We regularly represent clients in audits and assist in responding to IDRs. If the dispute cannot be resolved through negotiation, we advocate for clients in adversarial proceedings before the service and in federal and state courts.