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
- January 24, 2012
Alex Sadler Comments Regarding Third-Party Return Information Disclosure Exception
Tax Analysts - January 23, 2012
Bob Stack Quoted in Reuters Article on Romney's IRA
Reuters - December 7, 2011
Ivins Attorney Presents at BNA CITE International Tax Seminar - 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 - 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 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 - 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 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 - February 22, 2011
Ivins Attorneys to Speak at the FBA Annual Tax Law Conference - February 17, 2011
Ivins Attorneys Speak at TEI Event - December 9, 2010
Danielle Rolfes to Speak at GWU/IRS Institute on International Taxation - 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 24, 2010
Bob Stack Speaks to ABA on Economic Substance Codification - September 24, 2010
Joshua Brady Speaks to ABA Tax Section Meeting On Consolidated Returns - May 18, 2010
Danielle Rolfes to Speak at DC Bar Taxation Section/International Tax Committee Luncheon - April 29, 2010
Robert Stack Speaks to DC Bar on Cross-Border M&A transactions - April 5, 2010
Danielle Rolfes to Moderate International Tax Panel at ABA Tax Section May Meeting - 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 - March 5, 2010
Danielle Rolfes Chairs FBA International Panel - January 21, 2010
Bob Stack Qualified as Expert in Tax Court of Canada - January 6, 2010
Robert Wellen Comments on All-Cash D Regulations - December 4, 2009
Danielle Rolfes Co-chairs Symposium on Tax Issues Relevant in Emerging from an Economic Downturn - September 30, 2009
Leslie Schneider Comments on Proposal to Repeal LIFO
Tax Notes Today - Fall 2009
Danielle Rolfes Appears on ABA Panel on International Tax Reform - 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 - July 2009
Danielle Rolfes Elected to AICPA Tax Executive Committee - July 1, 2009
Danielle Rolfes Elected to DC Bar Tax Section Steering Committee - May 5, 2009
Bob Stack Moderates Discussion of Transfer Pricing in Developing Countries - April 28, 2009
Joshua Brady Speaks at D.C. Bar Tax Annual Consolidated Return Program - 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 - July 18, 2005
Identifying 10 Leading Tax Lawyers
Legal Times
Strategies & Opportunities
Publications
- 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 - 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 - 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 - 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 - September 14, 2009
Proposed Basis Recovery Regulations
BNA Tax Management Memorandum - August 3, 2009
International Tax Proposals Raise Technical Issues
Tax Notes - December 2008
Recovery of Madoff-Related Tax Losses
Ivins, Phillips & Barker - May 1, 2008
Maximizing the Benefits of Sec. 199 in an Asset Sale
The Tax Advisor - March 2007
Outline of Thoughts on Corporate Distributions
The Tax Magazine - 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. - 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 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 - October 8, 2004
Section 165(g)(3) and Section 332 Memorandum
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 - 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 - April 3, 2000
87 Tax Notes 103 - Mergers & Acquisitions: Questioning Rev. Rul. 96-29's Scope
2000 Tax Analysis Tax Notes - 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 - October 1992
IRS Determines Asbestos Removal is Capital Expenditure
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 - 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 - 1969
Financing Foreign Operations Through Domestic Finance Subsidiaries
Virginia Law Review