> Business & Taxation > Taxation

Tax considerations touch most aspects of doing business in the United States, and thus providing advice and assistance in tax related matters is an important part of our practice. We have two attorneys with advanced legal degrees in taxation, one with over 30 years of experience, to assist our clients in their efforts to minimize the tax implications involved with their business decisions. Our help includes both tax planning and the representation of clients in tax disputes with state and federal governments. Our role, however, is not intended to replace the invaluable assistance of a qualified accountant, and we prefer to work closely with our clients' accountants.

• Tax Planning: We frequently meet with clients and their accountants to plan business transactions and operations in a tax efficient way. The result of such planning may lead to changes in business operations, tax free spin-offs of business divisions, mergers, more formal contracts between related entities, use of new or different business entities, etc. Once a plan is developed, we prepare all documents needed to implement the plan. Our goal is not to complicate our client's business structure, but to insure that it is accomplished efficiently and with the least, adverse tax cost.
• Tax Disputes: We do not prepare income tax returns. However, if the handling of tax matters by clients or their accounting professionals is challenged by either the state or federal taxing agencies, and if the challenge is not successfully resolved by the client's CPA during the audit, we represent taxpayers in the appeals process. Our representation occurs both at the administrative level before an appeals officer, as well as in both state and federal tax court. We also represent taxpayer's seeking refunds in the Federal District Courts and on appeals to the Federal Circuit Court for the Ninth Circuit.
• Property Taxation: One area where periodic disagreement can occur relates to the value of property for property tax purposes. Most residential property tax disputes are too small to warrant legal representation; however, we regularly assist owners of commercial and industrial properties in disputes regarding the value of their properties by the local assessors. In these cases, we work closely with qualified appraisers to prepare and present our client's cases at both the Board of Property Tax Appeals and the Oregon Tax Court (regular and magistrate division). Often, a successful appeal results in very significant tax savings on large properties.

Representative Transactions:

• Separation of business divisions and distribution to corporate shareholders by tax-free spin-off in an effort to minimize future management disputes.
• Representation of Oregon corporation in tax-free acquisition by merger with large, publicly held acquirer.
• Representation of taxpayer in significant victory in appealing adverse decision by the U.S. Tax Court to the Federal Circuit Court for the Ninth Circuit Court of Appeals.
• Representation of property owners involving appeals to the Oregon Tax Court which have saved clients hundreds of thousand of dollars in property taxes.