The attorneys in Arnall Golden Gregory LLP's Tax Practice Group provide services in a number of different areas of tax law. The firm's emphasis is on bringing a high level of tax proficiency to bear upon a client's needs in order to develop creative solutions to problems.
Attorneys in the Tax Practice Group have developed their proficiency through formal education and work experiences. All of the tax attorneys have formal education in tax law, several have advanced degrees in taxation, and most have extensive educational or practical experience in related disciplines such as accounting or economics. These formal skills have been broadened through practical work experiences in the tax conflicts, tax planning, and employee benefits areas. As a result, the firm's attorneys possess diverse skills applicable to client needs across the spectrum of tax law.
The following is a brief description of typical activities that the firm's tax attorneys have engaged in:
Tax Conflicts
Attorneys are often involved in representing client interests in dealing with the Internal Revenue Service and relevant state revenue departments. Additionally, attorneys have represented client interests in both civil and criminal tax matters at both the federal and state court level.
The firm's attorneys have been successful in client representation in the tax conflicts area. In one such effort, the firm's attorneys successfully protested an erroneous IRS assessment pertaining to the proper characterization of intercorporate loans. In another such effort, the firm negotiated settlements in contested tax assessment proceedings, without resorting to the judicial process.
Tax Planning
Attorneys engage in tax planning activities for numerous clients, ranging from complex corporate reorganizations involving publicly-traded companies to planning appropriate business structures for small businesses.
Corporate planning activities that the AGG's attorneys have been involved in include corporate acquisitions, dispositions, reorganizations and formations. In one typical transaction, the firm's attorneys structured a leveraged buyout of a company to minimize tax consequences. In other matters, the firm's attorneys have counseled clients on the appropriate corporate tax treatment for a particular entity (regular versus subchapter S corporate election), and on creative ways of structuring the purchase price of businesses to minimize tax costs.
The firm's tax attorneys have similar experience in partnership tax planning. The firm's practice involves working with both public and private general and limited partnerships in the formation, operation, and sale or liquidation of such entities. The firm's tax attorneys are skilled in the planning required by partnerships to minimize tax consequences and comply with increasingly complex regulatory requirements.
International Tax Services
In the International area, the firm services both foreign investors in the U.S. ("inbound" transactions) and U.S. investors abroad ("outbound" transactions). The firm's attorneys keep current in international tax matters to provide effective counseling in transactions involving international tax implications. The firm's attorneys have had considerable experience in international transactions involving U.S. real property that are potentially subject to the Foreign Investment in Real Property Tax Act (FIRPTA). Additionally, one recent example of an outbound transaction involved a client's need to establish a foreign sales corporation (FSC) to expand its markets to other countries.
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