Tax
The Tax practice group at Forchelli Deegan Terrana LLP advises businesses and high-net wealth individuals on all facets of income and other business-related taxes. We provide tax counsel in connection with entity formations, equity issuances, distributions, reorganizations, redemptions, mergers and acquisitions, and business divorce. We advise on tax provisions in partnership and LLC operating agreements, shareholder agreements, buy/sell agreements, and redemption agreements. We help clients with state and local tax issues including residency, nexus, source of income, and successor liability. We also collaborate with employment, matrimonial, and litigation attorneys to structure tax efficient settlement agreements.
The group consists of attorneys with L.L.M.s in Taxation from New York University or who are a Certified Public Accountant.
Our business clients range from private equity funds, closely-held family businesses, middle-market companies, and start-ups. We advise entrepreneurs, investors, executives, and service providers being issued incentive equity or qualified small business stock (QSBS). We also advise clients on the formation, registration, and operation of not-for-profits and foundations, and coordinate the process of obtaining tax-exempt status.
The group represents clients with tax controversy matters before the IRS and state tax agencies during audits, administrative appeals, and Tax Court litigation. We advocate for businesses on issues such as bad debt, the value of minority interests, the employee retention credit (ERC), and cancellation of indebtedness; and individuals on flowthrough items, real estate professional status, and penalty defenses.
The Tax practice group assists those with unfiled returns or international reporting obligations, such as FBAR and Form 3520, and participation in Voluntary Disclosure Programs. We guide clients through audit reconsideration, and refund claims, and have successfully obtained several private letter rulings. We resolve collections matters through installment payment arrangements, offers-in-compromise, currently not collectible status, and innocent spouse relief. We also have significant experience in tax shelter investigations for both taxpayers and alleged promoters.
