Federal partnership taxation, including tax planning and counseling in connection with the formation, capitalization, operations and terminations of entities taxed as partnerships.
Tax planning and compliance counseling with respect to structuring mergers, acquisitions, disposition and business transactions to minimize taxes and comply with federal tax laws.
Counseling Michigan’s largest healthcare provider, and subsidiaries with respect to the federal New Markets Tax Credit Program.
Tax counsel with respect to various federal and state tax credit transactions and economic development incentives on behalf of developers, alternative energy businesses, community development entities and tax credit investors, including federal New Market Tax Credits, Michigan Historic tax credits, Michigan Brownfield tax credits and other federal and state tax incentives.
Tax counsel for the issuance of tax-exempt bonds, including governmental bonds and Private Activity Bonds, ranging in size from $1,000,000 to over $500,000,000.
Tax counsel to non-profit entities with regard to formation, exempt status, UBIT and transactions with for-profit entities.
Counsel to clients in tax controversy matters before the United States Tax Court, Internal Revenue Service and state agencies.
Auto Club Life Insurance Co. v. Commissioner, T.C. (2006) - (successfully prevailed in obtaining a full concession from the Internal Revenue Service to preserve several million dollars of federal small life insurance company deductions).
TG Missouri Corp v. Commissioner, 133 T.C. No. 13 (2009) – (successfully represented taxpayers in lead national case involving interpretation of statutory provisions allowing for the federal Research Credit).