Tax

The Income and Business Tax group of Butzel Long provides a wide variety of services involving Federal, state and local income and business taxes. The Income and Business Tax group advises and consults on the tax implications of proposed and executed transaction. We will provide tax analysis of proposed transactions and provide advice on alternatives to address particular tax costs or take advantage of tax savings. Some of the avoided tax costs or obtained savings are immediate and direct, and others are long term in nature. Advice on completed transactions will involve the likely treatment by the governmental agencies and more importantly, an analysis of the sustainability of more favorable tax treatment. Our advice ranges from informal written advice to formal opinion letters.

The advice can relate to the structuring of a business organization including the choice of entity. Often we are asked to assist our corporate group with structuring mergers, acquisitions, divestitures and other similar transactions. Our capabilities extend beyond transactions and into structuring employee ownership plans, exit strategies, and ordinary course transactions. We often are requested to assist tax preparers with the reporting of transactions on the applicable tax returns who will often look to us to provide technical expertise.

Our services extend beyond giving advice to the defending of tax positions of clients regardless of our prior involvement. Our tax controversy services can start with handling and providing advice in connection with inquiries from or audits by taxing authorities and lead to representing clients in administrative appeals or litigation. Our services range from providing an objective review of issues and advice regarding the strength of positions taken to developing the defense of positions taken and presentation and negotiation with taxing authorities. Furthermore, we provide insight into the initiatives of taxing authorities to gauge the likely stands and challenges by the taxing authorities. Our goal is to defend and advocate on behalf of our clients and to provide analysis of issues for our clients to assess the economic impact of adverse determinations and the cost of appealing those determinations.

MORE ATTORNEYS
  • Prepared numerous filings and applications to present to the Internal Revenue Service on behalf of clients to facilitate the determination that the clients’ employee pension benefit plans remained tax-qualified.
  • Assisted Lakeshore Engineering Services Inc. in their acquisition of Toltest Inc., creating Lakeshore Toltest Corp., one of the largest federal and municipal contracting companies in the Midwest.
  • Represented major law firm partner in income tax fraud matter.
  • Filed amicus curiae brief with the U.S. Supreme Court on behalf of 13 state-specific mutual-bond funds, addressing the issue of whether income-tax exemption for interest income from in-state municipal bonds violates the Constitution's Commerce Clause
  • Sales tax/use tax litigation; summary judgment for taxpayer
  • Successfully resolved an IRS claim for penalties relating to foreign financial accounts (FBARs) for $20,000, when IRS position would have led to penalties of $10,000,000 and a realistic projection of penalties was in the vicinity of $500,000.
  • IRS audit re auction house's 401(k) plan contributions