Tax Law

The word “tax” by itself elicits a visceral response for many people, and rightfully so: It’s your money or someone else’s money that you must protect. It is difficult to understand and properly comply with tax codes and the associated regulatory provisions are often confusing, sometimes contradictory, and provide for harsh monetary and/or criminal penalties. This is particularly true for businesses, and especially for those operating in multiple states, that must dedicate significant time to sort out and plan for tax and other compliance issues. And while most people think of the IRS when tax is mentioned, many states have also become aggressive in assessing and collecting taxes related to operating a business.

Tax Planning

At Protorae Law, we are dedicated to protecting our clients through federal and state tax planning services and take the time to fully understand each client’s situation, motivations, and goals. From state nexus checkups for our multistate clients, to business planning and formation, our experienced and highly skilled attorneys will provide the best options to drive your success.

Our attorneys have helped numerous large and small businesses, non-profits and individuals plan for and navigate federal and state tax issues.

Tax Controversy

If you should find yourself in a dispute with a taxing authority, we can help. By taking a solutions approach with government taxing agencies and presenting tax issues properly, we routinely have a receptive audience for advantageous negotiation. If an acceptable resolution cannot be reached through the initial negotiations, then we will zealously advocate on your behalf in administrative and court proceedings against the IRS or any other taxing authority.

Our Tax Services Include:

• Nonprofit – including Foundations, Hospitals, Colleges & Universities, Charitable Trusts, Religious Institutions, and Trade Associations
  • Formation
  • Corporate Governance
  • Business Transactions
  • Federal, State and Local Compliance
  • Tax-Exempt Financing
  • Compensation & Benefits
• State and Local Tax
  • Corporate Income
  • Sales and Use
  • Franchise
  • Excise
  • Transfer Tax
  • Unclaimed Property and Voluntary Disclosure Programs
  • Tax Credits
  • Room & Occupancy
  • SaaS and IaaS
  • Nexus
• Federal and International
  • Corporate
  • Partnership
  • Individual Income Tax
  • Tax Credits (Research, Low-Income Housing, Renewable Energy)
  • Corporate Inversion
  • Streamlined Foreign Offshore Procedures
  • Employment
  • FATCA
  • FIRPTA
  • Trust and Estate
  • Pension Plans

Representative Matters:

• Negotiated $11.5M reduction in IRS tax assessment for international private client prior to scheduling appeals conference.
• Successfully defended partnership client in tax credit recapture dispute with the State of Oregon and IRS, resulting in no adjustment letter being issued for the $3.9M proposed tax credit recapture.
• Negotiated IRC 501(c)(3) educational institution’s California tax assessment to $0 in advance of any administrative or other proceedings and subsequently advised client on tax compliance matters in 14 other states and Puerto Rico.
• Successfully defended IRC 501(c)(3) religious organization from multi-million-dollar IRS employment tax audit and assessment.
• Negotiated 80% reduction in IRS employment tax audit assessment for California municipality prior to scheduling appeals conference.
• Successfully represented manufacturer in IRC 199 multi-million-dollar deduction dispute with IRS in U.S. District Court.
• Advised investment client on availability of $10M+ in Economic Redevelopment and Growth credits from prior deal that client had erroneously been advised were not available.
• Represented dual citizen in multi-million-dollar FATCA compliance and reporting for individual income tax and corporate income tax for three foreign companies.
• Advised large media holding company on numerous media company acquisitions and charitable foundation creation and governance.
• Represented national retailer in multi-year unclaimed property dispute with State of Delaware, resulting in 90% reduction in liability.
• Advised multiple private art collectors on strategy to save millions in sales and use tax for art purchased at auction in NY and CA.
• Represented IRC 501(c)(3) international hosteling organization in room and occupancy tax dispute with Massachusetts Department of Revenue.
• Advised global information services company that provides cloud-based services to national and international clients on nexus, sales and use tax withholding, and filing compliance.
• Advised Japanese trading company on Federal permanent establishment rules and state employment tax implications in Florida, Alabama, Louisiana, and Texas.

LEGAL DISCLAIMER: THE RESULTS OF ALL CLIENT MATTERS DEPEND ON A VARIETY OF FACTORS UNIQUE TO EACH MATTER. PAST SUCCESSES DO NOT PREDICT OR GUARANTEE FUTURE SUCCESSES.