Tax

Tax laws and related issues are constantly evolving and changing. Businesses and individuals face new rules and provisions, increased audits, higher tax rates and technological advancements that can make it difficult to understand and manage federal, state and local taxes. Our tax attorneys are primed to help our clients understand these intricate tax laws, to navigate trends, realize tax savings and capitalize on opportunities to save money. Our attorneys help clients with their business and individual income and other tax matters on the federal, state and local levels. We have in-depth experience and knowledge and have advised clients in the banking and finance, commercial, real estate, technology, oil and gas, mining, telecommunications and public utilities arenas.

New, Emerging and Growing Businesses

We advise new, emerging and growing businesses with the tax choices that can be key to their growth and prosperity. We help our clients select the right organizational structure for their business, including general and limited partnerships, limited liability companies, subchapter “S” and “C” corporations and non-profit corporations. We structure borrowings, venture capital and other private placements, public offerings and other tax-free contributions to capital. Our attorneys provide creative tax advice in structuring and implementing complex compensation plans including grants of equity, profits interests, equity participations, incentive and nonqualified statutory stock options, restricted stock, phantom stock and other compensation plans.

Corporate Tax Matters

Our attorneys provide creative tax advice in corporate matters, advising boards and tax directors in connection with numerous federal and state tax issues, including formation, business operations, tax reporting, consolidated group structuring, reorganizations, and when necessary, on dissolution of the corporate structure.  Tax Audits and Controversies We represent clients with all federal, state and local dispute resolution at all levels, and help companies deal with legal issues that accompany audits or tax appeals. We regularly handle Internal Revenue Service audits and protest letters contesting tax adjustments and penalties, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation. We have experience representing clients in federal and state tax matters in the courts and before tax authorities. Our tax attorneys are admitted to practice with the United States Tax Court, federal district courts, a number of states and U.S. Courts of Appeals, and they collaborate with our local counsel network to resolve tax disputes virtually anywhere in the U.S. and around the world.

Partnerships and Limited Liability Companies

Partnerships and other pass-through tax entities can take many forms, each with its own tax advantages and special organizational requirements.  We structure partnership and limited liability company arrangements as pass-through tax entities in accordance with complex and ever-changing tax laws and regulations. Our attorneys have extensive experience in organizing general and limited partnerships, limited liability companies and joint ventures. Our lawyers deal with a range of tax issues pertaining to the formation of partnerships, the addition of new members, the sale of partnership interests, partnership operations, the retirement of members, the liquidation of partnerships, and the issuance of partnership interests for services. We frequently draft partnership documents and understand the complexity of the business and tax issues they address.

Mergers, Acquisitions and Reorganizations

We are well-versed in all federal and state tax aspects of business combinations involving stock and asset purchases and sales, leveraged buyouts, mergers, and spinoffs, including tax-free reorganizations through acquisition and divestiture.

Tax Audits and Controversies

We represent clients with all federal, state and local tax dispute resolution at all levels, and help companies deal with legal issues that accompany audits or tax appeals, including unclaimed property audits under state escheat laws. We regularly handle Internal Revenue Service and Utah State Tax Commission audits, and protest letters contesting tax adjustments and penalties, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation. We have experience representing clients in federal and state tax matters in the courts and before tax authorities. Our tax attorneys are admitted to practice with the United States Tax Court, federal district courts, a number of states and U.S. Courts of Appeals, and they collaborate with our local counsel network to resolve tax disputes virtually anywhere in the U.S. and around the world.

Individuals and Families

We assist clients with their individual income tax matters, including income tax planning, arranging and documenting charitable gifts (including establishing charitable trusts and private foundations), planning for capital gains transactions, documenting simultaneous and deferred like-kind exchanges. We help individuals prepare wills, living trusts, health care proxies, and durable powers of attorney. We also prepare insurance trusts, charitable trusts, qualified personal residence trusts, family limited partnerships, limited liability companies, foundations and other sophisticated estate planning tools. Additionally, we handle probates, administration of trusts and estates, and the preparation of state and federal estate tax returns.

Nonprofit Organizations

We represent nonprofit and tax-exempt entities, as well as high-net worth nonprofit donors, to advise them on their organization and operations.  We advise them on formation, incorporation, tax-exempt qualification, maintenance, reorganization, restructuring and legal termination, and we have skill helping individuals with charitable lifetime and testamentary planning. As part of our representation of charitable and nonprofit organizations, we obtain and maintain exemptions from federal income, state franchise and sales use, and local ad valorem taxes. We also assist our clients with compliance with Internal Revenue Code provisions and IRS rulings, Treasury regulations, judicial decisions, state tax and charitable solicitation statutes, and administrative regulations.