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Tax: Federal

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Because Miller Canfield federal tax lawyers provide innovative and creative solutions to complex and routine federal tax problems, we continue to be the tax counsel of choice for numerous domestic and international corporations, closely held businesses, partnerships and high net worth individuals. Our attorneys formulate advantageous tax strategies for creating and buying business entities, selling, restructuring and liquidating operations of all types and sizes. And, we deliver tangible value in counseling and representing clients in high exposure contested matters – both administratively before the IRS and in litigated matters before federal courts. 

Of additional and enduring benefit to our growing cadre of large and small multinational clients is the skill Miller Canfield attorneys bring to international corporate tax planning.  

Our demonstrable commitment to providing responsive, enlightened service and utilizing the efficiencies of first rate technology confirms to clients that they are represented by counsel with mastery of the tax aspects of securities transactions, issuance of tax-exempt obligations, and international finance transactions, among other complex corporate transactions.     

  • Assisted numerous U.S. taxpayers residing both in the U.S. and abroad with tax compliance issues related to foreign bank/financial accounts, foreign trusts and other foreign business/investment entities. Advised numerous individuals in connection with making voluntary disclosures of their prior failure to file required U.S. tax/financial information returns (such as the "FBAR" Form, as well as Forms 5471, 3520 and 8938, etc.) and how to address  previously unreported U.S. tax liabilities.
  • Established Delaware Statutory Trust to enable like-kind exchange treatment for oil and gas investments
  • Restructured company to enable owners to avoid net investment income tax upon sale of company
  • Restructured limited liability company sale to enable company to deduct proceeds payable to departing owner
  • Assisted major school district in resolution of claim by IRS of constructive receipt income by teachers
  • Provided critical analysis and opinion on the tax status of financial products sold in a public offering
  • Developed and coordinated the tax planning for a stock and asset acquisition by a foreign client of companies in 13 countries
  • Challenged IRS conclusion that income earned by a company owned by a client constitutes foreign base company income
  • Defended a tax-exempt entity against an IRS proposal to revoke the company's tax-exempt status and to impose penalties upon the officers for the receipt of excess benefits
  • Partnership mergers
  • Tax issues arising from asset and stock sales
  • Evaluation of workers' status for employment tax purposes and the potential tax ramifications of that issue
  • Tax issues arising from a variety of fringe benefits offered as part of an employment package to a recruited executive
  • Tax ramifications arising from the settlement of various forms of litigated disputes
  • Like-kind exchanges and various forms of corporate combinations, reorganizations and dispositions