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Practice Highlights

  • Tax planning for businesses and individuals
  • Tax dispute resolution
  • Wealth transfer and estate planning and administration

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Tax and Estates

Our goal in the tax and estates practice group is to help you determine which route will get you to your objectives with a minimum tax burden. Our lawyers, together with our colleagues in various practice groups throughout the firm, work with you to identify the most tax-efficient solutions available.

Whether you are a business owner considering the expansion or sale of your business, a party settling a lawsuit, a family member interested in a tax-efficient means of passing wealth, or the administrator of an estate, our lawyers and other professionals rely upon their many years of experience across multiple tax disciplines to identify overlooked opportunities that could benefit all interested parties. 

We carefully evaluate the needs of our clients in order to formulate effective tax saving solutions. Our tax and estates attorneys are well-versed in several sub disciplines, hold advanced degrees, and bring to bear years of experience in both government and the private sector. This depth allows us to assist a management team considering a corporate transaction, families considering complex estate planning matters, and the personal representatives of an estate navigating challenging waters. We regularly provide timely advice to closely-held businesses, entrepreneurs, large corporations and their shareholders, tax-exempt organizations, partnerships, limited liability companies, S corporations, and multi-generational families. We also regularly work with private equity funds, investment bankers, financial, accounting, insurance, and other professional advisors.

We provide practical legal solutions related to:

  • Business formation and choice of entity
  • Taxable and tax-free mergers, acquisitions and divestitures
  • Real estate transactions, including Section 1031 like-kind exchanges
  • State and local tax planning
  • International taxes, including investment structuring, treaty issues, and transfer pricing
  • Executive compensation, including non-qualified deferred compensation plans
  • Charitable giving and tax-exempt organizations
  • Individual estate and income tax planning
  • Wills, trusts and elder law planning
  • Estate and trust administration and probate litigation
  • Tax dispute resolution

Tax

Our lawyers assist clients with issues such as federal, state, local and international tax planning and the formation, operation and liquidation of various business entities. Our goal is to develop practical approaches that are consistent with individual and business objectives while reducing the overall tax burden. Working closely with clients, their other professional advisors and lawyers in other practice groups at White and Williams, we help to structure and implement taxable and tax-free business and investment transactions involving individuals, corporations, partnerships, limited liability companies, S corporations, trusts and estates.

Estate Planning and Administration

We guide individual clients and their families to plan for their long-term needs while being sensitive to their current needs and desires. These plans allow for the passage of wealth to later generations while minimizing the federal and state transfer tax burden. Our lawyers regularly counsel individuals on ownership succession for closely-held businesses and lifetime gifts. As part of our estate planning practice, we have developed significant experience in the design and use of irrevocable life insurance trusts, qualified personal residence trusts, family limited partnerships and limited liability companies, charitable remainder trusts and private foundations, generation-skipping trusts, grantor retained annuity trusts, and other sophisticated estate and income tax savings techniques. 

Dispute Resolution

Our lawyers regularly represent clients before various administrative agencies and courts, including the Internal Revenue Service, U.S. Tax Court, state and local taxing authorities and numerous state probate tribunals. We have represented clients before the IRS and numerous state taxing authorities in defending a variety of tax return positions. We also have successfully navigated the complex procedural issues presented by advance ruling requests, tax audits, administrative appeals, and tax litigation. We also have significant experience in representing clients with offshore account disclosures, including the IRS Voluntary Disclosure Programs and the state counterparts.

Representative Matters

Tax

  • Worked with the owner of a privately held business in its acquisition by a private equity firm while deferring a significant portion of the owner’s gain from the ‘sale’ of such business
  • Worked with a number of clients to qualify for and utilize state income tax credits to minimize their overall tax burden and improve the bottom line
  • Worked with numerous board of directors and other business owners to create equity incentive compensation plans for key employees that provided significant income tax benefits, including deferral of the recognition of income 

Estate Planning and Administration

  • Represented a family of a closely-held family business in designing the transfer of the business to the 5th generation, by designing a transaction structured as a sale which did not yield income taxes and shifted ownership to the next generation without incidence of the gift tax
  • Represented numerous clients in designing trusts and other arrangements for their family members that have special needs in order preserve assets, and allow the beneficiary to continue receiving the greatest level of support from other private and public sources

Dispute Resolution 

  • Represented a family business in a multifaceted IRS audit that resulted in a settlement in U.S. Tax Court where the multi-million dollar assessment was substantially reduced.
  • Resolved multiple IRS audits on issues ranging from R&D tax credits, hobby losses, and depreciation adjustments, often with little or no adjustments.
  • Represented numerous clients in state and federal voluntary disclosure programs (including failing to report foreign bank accounts) avoiding hundreds of thousands in penalties, and reducing additional taxes and interest that would otherwise be payable to taxing authorities
  • Successfully represented a multi-state bank in administrative proceedings, as well as before state appellate courts including the state Supreme Court, challenging a state tax assessment of several hundred thousand dollars

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