Tax Planning and Controversy Resolution

Tax Planning

Stein Law is active in all stages of business formation and operation, beginning with planning and selecting legal entity structures appropriate not only for our clients’ short-term objectives but also for their long term exit strategy. We have extensive expertise in business tax issues, including corporate and partnership tax, mergers and acquisitions, and international tax.

Stein Law also has a robust controversy practice where we represent taxpayers before the IRS and US Tax Court. We have extensive experience in all aspects of controversy from the initial contact with the IRS thru appeals process.

We represent clients on their inbound and outbound transactions and assist them in all aspects of compliance. While we do not prepare tax returns we work closely with their accountants to ensure all aspects of compliance are carefully followed. Our international clients include foreign manufacturers doing business in the US, foreign investors in partnerships, taxpayers caught in the foreign compliance programs, and estates of non-resident aliens with US based assets.

Finally, we have extensive experience in various tax credit programs from low income housing projects to New Markets Tax Credits, to conservation easements, to Historic Tax Credits to qualified opportunity zones. We assist our clients in obtaining allocations of New Markets Tax Credits and represent them throughout the process including negotiating terms and structure.

Among the recent tax services provided are the following:

  • Assisting the seller in the sale of a telematics company regarding gain classification and multi-national income tax issues
  • Preparation of gain recognition agreements to defer recognition of gain
  • Assisting an international life settlement company on the acquisition and disposition of life insurance policies and US presence issues
  • Foreign investments in US real estate and avoidance of, or compliance with, FIRPTA
  • Like Kind exchanges
  • M&A structuring and consolidations
  • Acquisition of companies with net operating losses
  • Corporate spinoff of wholly owned subsidiary
  • Excess loss accounts from loss generating subsidiaries
  • Tax Court litigation
  • Advising on estate taxation of US property of a non-resident alien
  • Captive insurance companies
  • Obtaining and documenting tax credit transactions including New Markets Tax Credits and Low Income Housing

Tax Controversy

Stein Law also has a robust controversy practice where we represent taxpayers before the IRS and US Tax Court. We have extensive experience in all aspects of tax controversy matters from the initial contact with the IRS through the appeals process.

We represent clients before the IRS and US Tax Court in employment tax issues, innocent spouse relief, foreign tax compliance, jeopardy tax assessments, estate and gift tax issues, income tax issues, and numerous other areas. We are brought in at every stage of engagement, audit, appeals, or court litigation.