Tax Planning and Litigation

Corporate Tax Attorneys

With over 100 years of collective experience, Parsons Behle & Latimer tax planning attorneys have developed a thorough understanding of the complex and constantly evolving tax laws. We provide dynamic and innovative solutions to issues related to federal and state income tax, excise tax, state franchise tax, tax withholding, estate tax, real estate tax, sales tax, property tax, and gift tax planning. Our tax lawyers draft tax-sensitive agreements, tax legislation, tax structuring, tax driven advice on choice of entity considerations and real estate purchase transactions, development and leasing transactions, and negotiation of tax controversies and settlements at the local, state and federal levels. We also provides comprehensive estate planning services focused on maximizing asset protection, minimizing estate and gift tax liability and reducing administrative costs.

Corporate and Business Tax Planning

Parsons Behle & Latimer tax attorneys, some of whom worked for governmental agencies in tax compliance and enforcement arenas, advise businesses of all sizes, at all stages of a company’s development, from start-ups to well established public companies, and across a range of industries, including mining, manufacturing, high tech, retail, wholesale, dealerships, franchises, energy exploration, utilities, transportation, just to name a few. Our tax attorneys work to legally minimize our client’s tax burden and keep them informed of new tax laws, regulations and pending litigation.

Our tax attorneys, working closely with Parsons Behle & Latimer’s corporate law group, have played major roles in structuring and negotiating the purchase and sale of businesses, divestitures, business combinations and spin-offs. Our tax practice also involves tax planning for the formation, operation and eventual liquidation of all forms of businesses including partnerships, limited partnerships, limited liability companies, series LLCs, joint ventures, S-corporations, C-corporations and tax exempt organizations. Although much of this work relates to federal taxation, we are noted for our knowledge and skill in state and local tax issues, particularly in the states of Utah, Nevada, Idaho, Wyoming, Washington and Arizona.

Attorneys focused on this area:

• Grimshaw,Randy M.
• Barusch, Lawrence R.
• Cook, Matthew D.

International Tax Planning

Our firm has special tax law skills advising clients and structuring transactions with respect to international tax issues. We have advised large and small firms around the country and overseas on foreign tax credits, controlled foreign corporations, foreign sales corporations, U.S. sourcing rules, tax treaties, permanent establishments, effectively connected income, foreign earned income exclusions, taxation of non-resident aliens, portfolio investment, real property holding corporations and withholding taxes.

Attorneys focused on this area:

• Grimshaw,Randy M.
• Barusch, Lawrence R.
• Cook, Matthew D.

Employee Benefits Plans

In today’s business landscape employee benefits plans are an essential tool in providing support, encouraging loyalty by aligning the employee’s interests to those of the employer, rewarding dedication and excellence and retaining the key personnel of businesses. Our tax attorneys regularly advise employers on the creation, maintenance and amendment of employee benefits plans in compliance with the complex and ever-changing tax laws applicable to such plans.

Our tax attorneys routinely advise employers on employee benefits plans and tax law issue related to:

• Incentive Stock Option Plans
• Employee Stock Purchase Plans
• ERISA Plans
• 409A Issues
• Welfare Plans
• Life Insurance Benefits
• Employee Stock Ownership Plans
• Severance Plans

Attorneys focused on this area:

• Grimshaw,Randy M.
• Barusch, Lawrence R.
• Cook, Matthew D.

Estate Planning and Wealth Management

Estate and wealth transfer planning is a necessity of life for most families, and even for families with modest assets, the tax implications of estate and wealth transfer planning can have a huge impact. Our wealth management services range from basic estate planning to planning for large estates, lifetime wealth transfers, asset protection and specialized planning for owners of closely held businesses, executives of publicly held corporations, international clients and other clients with highly specialized planning needs.

We assist clients with a wide variety of planning strategies, including:

• Inter Vivos Trusts (Living Trusts)
• Basic Wills and Testamentary Trusts
• Qualified Terminable Interest Marital Property Trusts
• Educational Trusts
• Crummey Trusts
• Life Insurance Trusts
• Grantor Retained Annuity Trusts
• Federal Estate Tax Planning
• Grantor Retained Unitrusts Trusts
• Charitable Remainder Trusts
• Planning for international or migratory clients
• Planning for highly compensated clients
• Planning for business owners, clients with stock or stock options on closely held corporations and other typical executive compensation issues
• Family Limited Partnerships and Limited Liability Companies
• Succession Planning For Closely Held Businesses

Attorneys focused on this area:

• Grimshaw, Randy M.
• Barusch, Lawrence R.
• Alderman, Kent B.
• Cook, Matthew D.

Tax Litigation

When it comes to tax controversies, clients look to Parsons Behle & Latimer for some of the most experienced trial lawyers in the Intermountain West. In fact, our litigation department is one of the largest and broadest in this geographic area. Many of our tax attorneys have experience with regulatory agencies and have litigated hundreds of tax cases including litigation in the United States Tax Court, United States District Court, United States Court of Claims, Federal Appellate Courts, and state tax and district courts throughout the Intermountain West. Our attorneys have also tried cases before boards of equalization, the Utah State Tax Commission, the Nevada Tax Commission, the Idaho Tax Commission, the Washington Tax Commission, and the tax and district and appellate courts in such jurisdictions

Our experience is in all areas of litigation and dispute resolution and our overall goal is to arrive at solutions that are fair and appropriate within the context of our clients’ needs. The bottom line is that we strive to resolve disputes in the most expedient and cost effective manner possible.

Attorneys focused on this area:

• Grimshaw,Randy M.
• Barusch, Lawrence R.
• Alderman, Kent B.
• Miller, Maxwell A.
• Leigh, Lawrence J.
• Cook, Matthew D.

Tax Advocacy

The tax attorneys at Parsons Behle & Latimer understand the challenges and concerns faced by our clients in confronting tax issues. We understand that resorting to tax litigation is often the last option in resolving a tax dispute. Therefore, our tax attorneys are experienced and work diligently to prevent the need for tax disputes to be litigated through actively engaging in tax advocacy.

Our tax attorneys work actively in the advocacy role through:

• Audits before the Internal Revenue Service, State Tax Commissions and local governmental taxing authorities
• Letter Rulings and declaratory ruling requests
• Refund Claims
• State and local tax legislation and rule making
• Providing tax opinions

Attorneys focused on this area:

• Grimshaw,Randy M.
• Barusch, Lawrence R.
• Miller, Maxwell A.
• Cook, Matthew D.

Property Tax Appeals

Parsons Behle & Latimer tax attorneys have extensive experience in property tax issues and have negotiated with property tax assessors throughout the states of Utah, Nevada, Idaho, and Wyoming. We have a thorough knowledge of the laws and procedures relating to the assessment of property taxes, which enables our tax attorneys to develop effective litigation strategies tailored specifically to property tax appeals.

A successful appeal of an adverse property tax assessment requires a determination of the market value of the assessed property. As a result, we assist our clients in analyzing market values for their properties and comparable properties in order to assess the likelihood of success during the appeals process. When necessary we engage highly qualified economists and appraisers to assist in the determination of market values, thereby increasing the likelihood of success in appeals before county boards of equalization, tax commissions, and the courts.

Attorneys focused on this area:

• Grimshaw, Randy M.
• Barusch, Lawrence R.
• Miller, Maxwell A.
• Cook, Matthew D.

Real estate tax planning and reduction

Parsons Behle & Latimer tax attorneys have extensive experience in working with real property tax issues from acquisitions, development, and disposition of real property assets, including 1031 non-recognition exchanges. Working in conjunction with our real estate banking and financing group, we assist our clients in developing the proper structure for each real estate transaction to minimize tax consequences and risks. We further assist our clients in obtaining tax credits at the state and federal level for qualifying projects such as the restoration of historic structures and low income housing. We also have extensive experience with conservation easements for charitable donations of real property.

Attorneys focused on this area:

Click here to view our representative tax litigation and administrative matters case list.

Contact: Max A. Miller, 801-536-6790, MMiller@parsonsbehle.com, Lawrence R. Barusch, 801-536-6760, LBarusch@parsonsbehle.com or Randy M. Grimshaw, 801-536-6779, RGrimshaw@parsonsbehle.com to learn more about ways we can help you resolve all of your tax planning and litigation issues.