Business Tax
Our attorneys regularly provide sophisticated tax planning for publicly traded and closely held corporations, limited liability companies, partnerships, and individuals, both in the United States and abroad. In addition, our lawyers represent clients in tax disputes with the Internal Revenue Service or state revenue departments. Whatever your tax planning needs, from the relatively straightforward, to complex matters most firms simply cannot handle, you can count on us for a creative solution.
We concentrate our tax planning advice and strategy in the following areas:
We work closely with our clients to create customized solutions that incorporate your tax, business and, as in the case of closely held businesses, estate planning needs. We regularly coordinate our tax advice with planning for employee benefits and executive compensation. Our lawyers stay on top of the constantly changing landscape of federal tax law and can notify you of any changes to the tax law that may affect you or your business.
We have offices in Washington, D.C. and Los Angeles, California and provide legal advice and services to clients both nationally and internationally.
News
- June 5, 2013
John Bates Speaks at DC Bar Meeting on Inbound Taxation - May 24, 2013
Amicus Brief Filed re: Sabena Loving; Elmer Kilian; and John Gambino v. Commissioner of Internal Revenue - May 24, 2013
Chambers USA Ranks Ivins as a Leading Global and DC Tax & Benefits Firm
Chambers USA - May 10, 2013
Alex Sadler Panelist for ABA Court Procedure & Practice Program - May 9, 2013
John Bates Speaks at ABA Meeting on Section 367 Guidance - April 28, 2013
Six Ivins Attorneys Named as 2013 DC Super Lawyers - April 25, 2013
Joshua Brady Speaks at NYC Bar Institute on Tax Aspects of M&A - April 24, 2013
John Bates Speaks at DC Bar Meeting on International Tax Issues - April 17, 2013
Jonathan Zimmerman Speaks at TEI Audits & Appeals Seminar - April 17, 2013
Robin Solomon Speaks on Benefits Policy at AU Law School - March 28, 2013
Funeral Industry Comments on Proposed Regs on Net Investment Income Tax
Tax Notes Today - March 20, 2013
Douglas Andre Moderates DC Bar Panel on International Tax Disputes - March 13, 2013
Rosina Barker Speaks to ALI-CLE on Pension De-Risking - March 8, 2013
Robert B. Stack Appointed U.S. Deputy Assistant Treasury Secretary for International Tax Policy - March 1, 2013
Ivins Attorneys Speak at Federal Bar Association Tax Law Conference - February 26, 2013
Practising Law Institute Consolidated Tax Return Regulations 2013 - February 6, 2013
ABA Tax Section Teleconference: Intra-Group Restructurings - January 25, 2013
John Bates Speaks to ABA on International Partnership Tax Issues - January 22, 2013
Benjamin Grosz Speaks at DC Bar Estate Planning Committee on the Use and Taxation of Powers of Appointment - January 7, 2013
Les Schneider Testifies at Public Hearing on the Proposed Regulations - December 2012
Ivins Comments on Proposed Regulations
Tax Notes - December 14, 2012
Amicus Brief Filed re: PPL Corporation and Subsidiaries v. Commissioner of Internal Revenue - November 27, 2012
Ivins Attorneys Speak at TEI New Orleans Chapter - October 30, 2012
Ivins Attorneys Speak at TEI Annual Conference - September 14, 2012
Rosina Barker Speaks to ABA on Pension De-Risking - 2012
Chambers USA Ranks Ivins as a Leading DC Tax and Benefits Firm
Chambers USA - May 31, 2012
Ivins Secures Post-Mayo Victory in Federal Circuit Invalidating Treasury Regulation -- Dominion Resources v. United States - May 31, 2012
Pat Smith to Moderate Panel on Post-Mayo Developments at Federal Bar Association Insurance Tax Seminar - May 2012
Ivins Attorneys Named to 2012 Washington DC Super Lawyers - May 3, 2012
John Bates Presents on Foreign Tax Credit Guidance Webinar - April 2012
Robert Wellen Speaks at J. Nelson Young Tax Institute on Contingent M&A Prices - April 2012
Robert Wellen Speaks at Ninth Annual Institute on Tax Aspects of Mergers and Acquisitions - April 18, 2012
Rosina Barker Speaks to State Bar of Michigan: Correcting 409A Failures - March 28, 2012
Robert Wellen Speaks at ALI-ABA on Taxable Acquisition Structures - March 2, 2012
Ivins Attorneys Speak at Federal Bar Association Tax Law Conference - February 27, 2012
Robert Wellen Speaks at Consolidated Tax Return Regulations 2012 PLI Course - February 17, 2012
Ivins Attorneys Speak at ABA 2012 Tax Section Meeting - January 24, 2012
Alex Sadler Comments Regarding Third-Party Return Information Disclosure Exception
Tax Analysts - December 15, 2011
Ivins Attorneys Speak at DC Bar on Estate Planning with Retirement Plan Assets - December 7, 2011
Ivins Attorney Presents at BNA CITE International Tax Seminar - December 1, 2011
Brenda Jackson-Cooper Joins Estate Planning Group - December 1, 2011
Ivins Attorneys Named Best Lawyers in Washington DC
Washingtonian - November 30, 2011
Ivins Attorney Presents to Young IFA Network on Foreign Currency Tax Issues Webinar - November 2, 2011
Ivins Attorneys Speak at 66th TEI Annual Conference - November 2, 2011
Rosina Barker Spoke at the NASPP 2011 Annual Conference - November 1, 2011
Ivins Named as Tier 1 Firm in U.S. News "Best Law Firms" Ranking - October 20, 2011
Ivins Attorneys Speak at 2011 ABA Joint Fall CLE Meeting - September 28, 2011
Ivins Attorneys Speak at Fort Worth TEI Meeting - September 23, 2011
Rosina Barker Gives 409A Presentation to the Southern Federal Tax Institute - September 19, 2011
Ivins Attorneys Speak at Cincinnati TEI Seminar - August 31, 2011
Ten Ivins Attorneys Named to 2012 Best Lawyers in America - August 22, 2011
Patrick Smith Quoted in Tax Analysts Article on Omissions from Gross Income Cases
Tax Analysts - August 17, 2011
Danielle Rolfes Appointed Deputy International Tax Counsel at Treasury - August 1, 2011
Ivins Attorneys Comment on Guidance under Section 355 - July 21, 2011
Alex Sadler Joins Tax Controversy and Litigation Group - June 9, 2011
Robert Wellen to Speak at Texas Federal Tax Institute - June 1, 2011
Ivins Attorney Comments on Guidance under Section 909
Tax Notes Today - May 8, 2011
Ivins Attorneys Named to 2011 Washington DC Super Lawyers - May 6, 2011
Ivins Attorneys Speak at 2011 ABA Tax Section May Meeting - April 29, 2011
Rosina Barker Spoke on Taxation of Executive Clawbacks - April 28, 2011
Ivins Attorney Speaks at Penn State Dickinson School of Law/New York City Bar Program - March 31, 2011
Ivins Attorney Speaks at ALI-ABA Corporate Taxation Program - March 30, 2011
Ivins Attorneys Speak at TEI Event - February 22, 2011
Ivins Attorneys to Speak at the FBA Annual Tax Law Conference - February 17, 2011
Ivins Attorneys Speak at TEI Event - December 23, 2010
CNBC Business News, "The Call" - December 16, 2010
Rosina Barker Speaks to DC Bar on Clawbacks - October 2010
H. Stewart Dunn Named Washington DC Tax Lawyer of the Year - October 21, 2010
Bob Wellen Speaks on Corporate Spin-Offs - October 1, 2010
Bob Wellen Speaks on Consolidated Return Corporate Acquisitions and Separations - September 25, 2010
Rosina Barker Inducted to ACEBC - September 24, 2010
Joshua Brady Speaks to ABA Tax Section Meeting On Consolidated Returns - Summer 2010
Ivins, Phillips & Barker Celebrates 75th Anniversary - July 14, 2010
Rosina Barker Speaks on 409A Corrections in ALI-ABA Webcast - June 15, 2010
Ivins Named as First-Tier Firm in U.S. News "Best Law Firms" Rankings - June 7, 2010
Rosina Barker appointed to BNA Pension & Benefits Advisory Board - April 12, 2010
Rosina Barker and Kevin O'Brien Publish Insights on Correcting 409A Document Failures - April 1, 2010
Danielle Rolfes Appointed Vice-Chair of ABA Foreign Lawyers Forum - March 29, 2010
Leslie Schneider Comments on Licensing Fee Decision
Tax Notes Today - March 17, 2010
Robert Wellen Comments on Proposed Amendment to Section 361
Tax Notes Today - March 8, 2010
Leslie Schneider Comments on Bonus Compensation Plan Liability
Tax Notes Today - March 8, 2010
Robert Wellen Comments on All-Cash D Reorganization Proposal
Tax Notes Today - February 24, 2010
Rosina Barker Speaks to DC Bar on 409A corrections - January 6, 2010
Robert Wellen Comments on All-Cash D Regulations - 2010
Ten Ivins attorneys named to the 2010 Best Lawyers in America - September 30, 2009
Leslie Schneider Comments on Proposal to Repeal LIFO
Tax Notes Today - September 24, 2009
Ivins Lawyers Address Silicon Valley Tax Directors Group Luncheon - September 14, 2009
Robert Wellen Comments on Schering-Plough Case
The Pink Sheet - August 20, 2009
Ivins Lawyers Present Article to BNA International Advisory Board Meeting - June 1, 2009
Matthew Bender publishes 3rd Release of Danielle Rolfes's FIN 48 Treatise - April 28, 2009
Joshua Brady Speaks at D.C. Bar Tax Annual Consolidated Return Program - Winter 2009
Chambers USA ranks Ivins as a leading DC Tax and Benefits firm - December 12, 2008
Joshua Brady Comments on Treasury Regulations
Tax Notes Today - October 21, 2008
Joshua Brady Speaks at D.C. Bar Tax Conference on Proposed Regulations - April 15, 2008
Joshua Brady Speaks at D.C. Bar Tax Conference on Consolidated Returns and Tax-Free Spinoffs - 2007
Brenda K. Jackson-Cooper Named in Chambers USA - July 18, 2005
Identifying 10 Leading Tax Lawyers
Legal Times - June 4, 2001
IP&B Wins Closely-Watched Case in Supreme Court
Ivins, Phillips & Barker - February 21, 2000
"One of the Last Pristine Tax Boutiques"
Legal Times
Strategies & Opportunities
Publications
- July 16, 2012
The APA's Arbitrary and Capricious Standard and IRS Regulations
Tax Notes - July 2, 2012
Waiting for Direction on Refund Penalties (quoted in article by J. Coder) - June 25, 2012
What We Didn’t Learn From Home Concrete
Tax Notes - April 2012
Appeals Restrictions in Cornyn Legislation Get Mixed Reaction
Tax Analysts - February-March 2012
Requests for Admission in Federal Tax Litigation: Uses, Limitations, Rules, and Strategic Considerations
Journal of Tax Practice & Procedure - March 12, 2012
DCL Separate Unit Combination and Foreign Use Rules Issues
Tax Notes - February 17, 2012
FATCA: Information Reporting Rules for US Individuals Holding Specified Foreign Financial Assets
Ivins, Phillips & Barker - January 30, 2012
Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax
Tax Notes - January 2012
Federal Circuit Clarifies Third-Party Return Information Disclosure Exception
Tax Analysts - January 16, 2012
The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices
Tax Notes - November 28, 2011
Is the Anti-Injunction Act Jurisdictional?
Tax Notes - January/February 2010
Charitable Lead Trusts -- A Win-Win Strategy for Donors and Charities
Taxation of Exempts - September 2011
Navigating the Research Credit
Tax Notes - September 2011
Overcoming Appeals' Bad Rap (quoted in article by J. Coder)
Tax Notes - August 30, 2011
DC Circuit: 'The IRS Is Not Special'
Tax Notes - July 11, 2011
Omissions From Gross Income and ‘Numerators and Denominators’
Tax Notes - June 20, 2011
Aggregate or Entity Theory of Partnerships for Currency?
Tax Notes International - June 20, 2011
Life After Mayo: Silver Linings
Tax Notes - May 18, 2011
Carter Hood Comments on New Law Governing Foreign Trusts with U.S. Beneficiaries - April 25, 2011
Mannella, State Farm, and the Arbitrary and Capricious Standard
Tax Notes - April 4, 2011
Omissions from Gross Income & Retroactivity
Tax Notes - February 14, 2011
Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules
Tax Notes - February 7, 2011
Avoiding Tax Casualties in the Currency War
Tax Notes - November 2010
Achieving Success in a Worker Classification Audit
Practical Tax Strategies - October 25, 2010
Mayo and Chenery: Too Much of a Shift in Rationale?
Tax Notes - September 27, 2010
Gaps in the Seventh Circuit's Reasoning in Lantz
Tax Notes - September 1, 2010
Schedule UTP: Ready or Not, Here It Comes
Tax Management Real Estate Journal - August 16, 2010
Omissions From Gross Income And the Chenery Rule
Tax Notes - August 2010
Contingent Consideration and Contingent Liabilities in Acquisitions
Ivins, Phillips & Barker - April 20, 2010
Codification of the Economic Substance Doctrine
Business Tax Insider - February 1, 2010
Brand X and Omissions From Gross Income
Tax Notes - November 30, 2009
Tax Savings Idea - Change in Treatment of Exchanges of Intangibles For Exchanges that Have Already Taken Place and Been Reported as Taxable
Ivins, Phillips & Barker - November 23, 2009
Check-The-Box Reform: (Subpart F)ishing with Dynamite
BNA Tax Management Memorandum - September 14, 2009
Proposed Basis Recovery Regulations
BNA Tax Management Memorandum - September 14, 2009
Seventh Circuit's Contilli Decision Clarifies Requirements for Post-Retirement Actuarial Adjustments
Ivins, Phillips & Barker - August 3, 2009
International Tax Proposals Raise Technical Issues
Tax Notes - July 22, 2009
Fry v. Exelon: How Will the IRS React?
Ivins, Phillips & Barker - June 25, 2009
Accelerated Deductions for Self-Funded Medical IBNR Reimbursements – Even Faster than You May Have Believed
Ivins, Phillips & Barker - May 12, 2009
Second Circuit Victory for PBGC in Oneida Will Make Distress Terminations in Bankruptcy More Expensive
BNA Pension & Benefits Reporter - December 2008
Recovery of Madoff-Related Tax Losses
Ivins, Phillips & Barker - Fall 2008
Taxing Tenure: An Examination of How the Federal Insurance Contribution Act (FICA) Has Been Applied to Tenure Buyouts
The Tax Lawyer Vol. 62, No. 1 - May 1, 2008
Maximizing the Benefits of Sec. 199 in an Asset Sale
The Tax Advisor - February 5, 2008
IRS Backloading Guidance Under Revenue Ruling 2008-7 -- Good and Not-So-Good News for Plan Sponsors
Ivins, Phillips & Barker - January 3, 2007
The W-2 Wage Limitation On the §199 Deduction: What W-2 wages and Who gets credit for them?
BNATAX Management - September 4, 2006
Musings on Selected Provisions of the Final §199 Regulations Applicable to Corporate Manufacturers of Tangible Property
Tax Management Inc. - Fall 2005
Accuracy-Related and Fraud Penalties After Enactment of the American Jobs Creation Act of 2004
Federal Bar Association, Section of Taxation Report - August 12, 2005
The Domestic Activities Production Deduction: Demystifying the International Tax Aspects
Tax Management International Journal - July 25, 2005
The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part II
Tax Management Memorandum - July 18, 2005
Leading Lawyers
The Legal Times - July 11, 2005
The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part I
Tax Management Memorandum - June 13, 2005
107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis
2005 Tax Analysis Tax Notes - June 6, 2005
Tax Bibliographies; Book Reviews, 107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis - December 2004
International and Corporate Tax Highlights of the American Jobs Creation Act of 2004, Tax Executives Institute
Los Angeles Chapter Meeting - November 2004
The American Jobs Creation Act of 2004: An Analysis of Selected Provisions
Ivins, Phillips & Barker - October 8, 2004
Section 165(g)(3) and Section 332 Memorandum
Ivins, Phillips & Barker - Fall 2003
Berger v. Xerox: Looking for Law in All the Wrong Places
Benefits Law Journal - Fall 2003
Accruing Benefits for Retired Ees: The Incredible Shrinking Ruling
Benefits Law Journal - June 19, 2003
Jobs and Growth Tax Relief Reconciliation Act of 2003
Ivins, Phillips & Barker - January 11, 2002
Transfer Pricing in the United States and Latin America
BNA Tax Management International Journal - Fall 2001
Flanigan v GE: Last Nail in the Coffin of the Asset "Sale" Bugbear?
Benefits Law Journal - Spring 2001
From the Editors: Scrivener's Error--An Overdue Doctrine for Qualified Plan Corrections
Benefits Law Journal - Fall 2000
Microsoft TAM--Answers Some Questions, Raises Others
Benefits Law Journal - October 13, 2000
What Tax Lawyers Should Know About Trade Law
BNA Tax Management International Journal - June 5, 2000
87 Tax Notes 1367 - Merging Disregarded Entities
2000 Tax Analysis Tax Notes - Spring 2000
Is There a Scriveners Error Doctrine
Benefits Law Journal - April 3, 2000
87 Tax Notes 103 - Mergers & Acquisitions: Questioning Rev. Rul. 96-29's Scope
2000 Tax Analysis Tax Notes - Fall 1998
Introduction and Hughes Blues
Benefits Law Journal - June 22, 1998
79 Tax Notes 1647 - Another Take on Peracchi
1998 Tax Analysts - 1994
Final UNICAP Regulations Expand Some Exceptions but Eliminate Others
Journal of Taxation - 1993
More Problems Complicate the Application of 'Substantially All' to Acquisitions
Journal of Taxation - 1993
New Final Regulations Offer More Flexibility in Defining Compensation
Journal of Taxation - 1993
New Guidance Is Needed for the 'Substantially All' Rule as Applied to Acquisitions
Journal of Taxation - October 1992
IRS Determines Asbestos Removal is Capital Expenditure
Journal of Taxation - July 1992
Final Regs. On Economic Performance Requirement Resolve Most Issues
Journal of Taxation - 1992
Improved Development of Complex Tax Legislation
American Journal of Tax Policy - January 1992
Who Incurs Environmental Clean-Up Costs - And Why - May Determine Deductibility
Journal of Taxation - 1991
When will Interest be Capitalized Under the New Proposed Regulations?
Journal of Taxation - 1990
Lessons from a Legislative Disaster
Tax Notes - 1990
The Law of Equal Employment Opportunity
Treatise - 1989
Minimum Coverage Prop. Regs. Contain Several New Tests
Journal of Taxation - 1988
PFIC Rules: Tax Policy Gone Awry
Tax Notes - August 4, 1986
32 Tax Notes 477 - A Revised Roadmap to Section 338
1986 Tax Analysis Tax Notes - 1986
Long-Term Contract Regulations: Endless Complexity and Planning Opportunities
Journal of Taxation - 1986
New Uniform Capitalization and Long-Term Contract Rules
Journal of Taxation - 1985
Premature Accruals and the Relationship Between Accounting Methods and the Penalty Provisions
Univ. of Southern California Law Center, Thirty-Seventh Tax Institute - January 1983
Advantages of New Tax Court Decision Allow Use of LIFO with Completed Contract Method
Journal of Taxation - 1982
International Implications of Internal Revenue Code Section 385 and Related Regulations
New York University Institute on Federal Taxation - 1981
An Analysis of the New Proposed Regulations on Use of Published Indices for Dollar-Value
Journal of Taxation - Insuring that special allocations of partnership income and loss are recognized
Taxation for Lawyers - Making the Most of Special Allocations of Partnership Income and Coping With Risks
Taxation for Lawyers - 1980
Options Available to a Corporation Acquiring its own stock from estate to deceased shareholder - 1969
Financing Foreign Operations Through Domestic Finance Subsidiaries
Virginia Law Review