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TAXATION
Betts Patterson & Mines enjoys a robust and varied tax practice. Members of the tax group are actively sought after by clients, accountants and other attorneys for their counsel.
Businesses face important local, state and federal tax decisions every day. Many of these are answered by staff or accountants. However, on occasion, the questions need more review or are presented by the taxing authorities, whether IRS, Department of Revenue or a local authority. Members of the Betts Patterson Mines tax group are well versed in local, state and federal taxes and regularly counsel businesses and their owners on taxes related to their operations, including, for instance, S Corporation elections and issues, state and federal constitutional issues for state and local taxes, tax audit issues, reporting requirements, corporate and partnership and LLC taxation and entity selection, gains on asset sales and entity liquidation, reorganizations, including mergers and spin-offs, and tax-qualified employee benefit plans.
Several members of the tax group have extensive estate planning practices which concentrate on transferring property among family members in the most tax efficient manner consistent with the desires of the client. Counseling clients on the disposition of their assets, whether by lifetime transfers or transfers which will take effect on death, requires the ability to determine a client's true objectives as well as the confidence to challenge a client on his or her preconceived notions on how to meet those objectives by recommending alternative methods. The Betts Patterson Mines tax group has the experience and talent to design a plan to best meet the client's objectives and assist in the implementation of the plan.
Analysis of tax opportunities and challenges always present in the formation or restructure of a business entity comprise a significant portion of the tax group's practice. The breadth of experience in matters of business law and estate planning gives Betts Patterson & Mines a unique perspective in counseling business owners on tax issues in the formation of business entities as well as taxes related to the operations of the business.
Controversies with government agencies on taxes are inevitable. The members of the tax group, together with the litigation resources of Betts Patterson Mines, are well positioned to protect the interests of clients in tax controversies with local, state or federal agencies. For instance, Betts lawyers prosecuted one of the very few successful equal protection state tax refund actions. Betts lawyers recently terminated a substantial accumulated earnings tax claim with a no change report.
The Betts Patterson & Mines tax group have represented:
- Business owners in the formation of new entities and the reorganization of existing business entities;
- Businesses in the preparation of complex, insured and unisured buy-sell arrangements;
- High net-worth individuals in managing their assets and counseling on tax efficient methods of transferring assets to family members or tax exempt organizations;
- Businesses and their equity owners in structuring and carrying out mergers and acquisitions and in spinning off unwanted businesses;
- Business operators in making tax sensitive decisions on business operations and the formation and restructure of the business entity
- Business and individual taxpayers in controversies and litigation with local, state and federal tax authorities;
- Estates and Trusts;
- Private Foundations; and
- Tax Qualified Employee Benefit Plans.
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