Dickinson Wright’s tax lawyers work with a broad array of clients including individuals, business entities, estates, trusts, nonprofits, governmental units and agencies, and other special purpose entities to ensure compliance with complicated tax laws and regulations at the federal, state, provincial and local levels. We regularly advise business clients at every stage, from planning and start-up through operations and dissolution, to minimize tax burdens and maximize profitability associated with transactions, investments, operations and other business activities.
Because tax consequences may follow from many aspects of business and personal activity, and tax decisions affect virtually every industry, our tax lawyers routinely work hand-in-hand with lawyers in each of Dickinson Wright’s dozens of legal practice groups and industry task forces. We regularly advise on the tax ramifications of litigation settlements, business transactions, asset distributions, executive compensation, and a broad range of other activities. Our experienced tax lawyers handle a wide array of tax controversies, including audits, appeals, administrative proceedings and tax litigation in both federal and state courts.
We have also challenged the assessment of sales and use taxes by the Department of Revenue and local governments and have helped formulate sales tax reimbursement mechanisms for developers and municipalities in connection with the development of a variety of real estate projects.
Among the taxation practice's areas of expertise are:
- Property tax planning and appeals, including: representation of individuals and municipalities in real and personal property valuation and related disputes, appeals and exemptions.
- Nonprofit and tax-exempt organizations, including: formation, operational compliance; IRS exemption letter applications/state exemption proceedings; restructurings; and other business transactions.
- International tax matters for both U.S. and Canadian companies operating abroad and foreign businesses operating in the U.S and Canada including foreign affiliate structuring and financing.; tax treaty benefits; and customs and excise tax matters.
- Partnership and joint venture structures involving U.S. and Canadian entities.
- Tax controversies and litigation, including: federal, state and provincial tax audits and assessments conducted by the IRS, the Canada Revenue Agency (CRA) and the Ministry of Finance (Ontario); state administrative appeals and informal conferences; IRS appeals; offers in compromise and litigation in the U.S. Tax Court, Canadian Federal Court and other federal, state and provincial courts.
- Business transactions, including: mergers; acquisitions; bankruptcies; tax-free restructurings and property exchanges; choice of entity; and tax planning involving a wide range of business formation, liquidation, investment and transactional issues, including transfer pricing.
- Tax issues in connection with business operations, including: equity, debt and hybrid investments; tax-advantaged borrowing; tax credit planning and state, provincial or local tax incentives; taxation of web-based transactions; worker classification; state unemployment tax issues; apportionment and multistate tax planning; sales and use tax compliance; executive and employee compensation issues.
- Directors' and Officers' liability issues, source deductions and other statutory remittances.
- Debt and debt forgiveness issues.
- Classification and treatment of damages and other awards.