Service
Tax
While tax simplification and fairness are concepts with universal appeal, the undeniable fact is that our tax system has grown increasingly complex and probably will continue to do so.
It remains the case that similarly situated taxpayers may face vastly different tax liabilities depending upon their ability to fit within available exceptions, exemptions and safe harbors provided by a complicated and constantly changing structure of statutory, regulatory, and judicial guidelines.
We counsel clients regarding:
Acquisitions and dispositions
- Limiting tax on acquisitions or dispositions (including state and local and transfer taxes)
- Structuring tax-free reorganizations
- Using pass-through entities to acquire businesses on a tax-deferred basis
- Enhancing future deductions
- Preserving existing tax benefits
Restructuring of entities and groups of related entities
- Tax-efficient workouts
- Achieving administrative efficiencies
- Avoiding triggering deferred gain
- Preserving deductions and losses
Individual tax matters
- Choice of business entity
- Planning for tax efficiency, including estate tax efficiency
Advocacy
- Exploring resolution at the lowest possible administrative level
- Presenting compelling written and oral arguments
- Rigorously prosecuting or defending tax matters in Tax Court, U.S. District Court or Commonwealth Court
Tax-exempt organizations
- Obtaining income tax, sales tax and real estate tax exemption
- Obtaining and maintaining public charity status
- Avoiding substantial unrelated activity
- Avoiding private inurement and impermissible private benefit
- Limiting unrelated business income tax
- Avoiding self-dealing, excess benefit and impermissible or unwise conflicts of interest transactions
- Meeting the charitable expenditures requirement
To assist companies in their resolution of tax problems, we deal regularly with the Internal Revenue Service and the Pennsylvania and Philadelphia Departments of Revenue. Through our association with the State Tax Committee of the United States Law Firm Group, we are able to assist clients with multistate tax issues in a comprehensive and efficient manner.
Our Tax Practice shares a strong foundation of technical tax knowledge and a broad understanding of current business practices. To that end, we are able to help our clients achieve their business and personal goals and objectives at the least possible tax cost consistent with the applicable law.
Partners in the Tax Practice frequently speak and write on tax issues. In the past year, our tax attorneys have participated in numerous continuing education programs sponsored by industry groups and the Philadelphia Bar Association.
Montgomery McCracken has a well-established reputation as a firm with the resources and talent to provide clients with outstanding service in all areas of federal, state, local, and international taxation.
Experience
Tax Leadership
SHARED THINKING
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