Tax Planning Services
Tax lawyer services including income tax planning, estate tax planning, gift tax planning, retirement planning and capital gains tax planning.  Preparation of legal tax opinion letters, tax projections, and tax counseling.   Tax planning and strategies for corporations, businesses, real estate owners and high net worth individuals. Consideration of federal, state, and multi-state tax planning issues. Tax reduction, tax deferral and tax compliance planning.  International tax planning.


Estate planning and tax savings strategies for high net worth individuals and sophisticated estates. Creation of trusts to include revocable living trusts, charitable remainder trusts (CRT’s), charitable lead trusts (CLT’s), special needs trusts (SNT’s), grantor retained annuity trusts (GRAT's), irrevocable grantor trusts (IGT's), irrevocable life insurance trusts (ILIT's), qualified personal residence trusts (QPRT’s), qualified terminable interest property trusts (QTIP’s) and qualified domestic trusts (QDOT’s). Estate tax, gift tax and generation skipping transfer tax analysis, projection and reduction strategies. Creation of family limited partnerships (FLP’s) and family limited liability companies (FLLC’s) with gift transfer strategies. Establishment and implementation of sophisticated “estate freeze” techniques. Utilization of “Dynasty” trusts for multi-generational legacies and generation skipping tax planning. Establishment of private family foundations and charitable estate and gift vehicles. International estate planning for dual citizens, foreign trusts and international estate tax analysis.  Probate administration for California and Washington estates.
Design, creation and qualification of retirement and benefit plans.  Creation and design of qualified retirement plans to include profit sharing plans, 401(k) plans, defined benefit pension plans, cross tested plans, cash balance plans, and employee stock ownership plans (ESOP's). Design and implementation of non-qualified plans to include executive compensation plans, supplemental executive retirement plans (SERP’s), top hat plans, deferred compensation plans, stock bonus plans, phantom stock plans and non-qualified retirement plans.  Creation of both non-qualified stock option plans and qualified incentive stock option plans (ISO’s).  Creation of health and welfare benefit plans. Pension plan administrative services including licensed pension actuarial services.  Pension actuarial calculations, analysis, design, tax compliance and pension tax return preparation to include Form 5500 and PBGC filings. Qualified Domestic Relation Orders (QDRO’s) and retirement plan asset valuation and division in dissolution of marriage.
Development and implementation of asset protection plans to preserve and protect individual and company assets and wealth.  Planning and protection from creditor claims and lawsuits.  Planning with Delaware, Nevada and Wyoming based companies and creditor protection trusts.  Formation of investment and asset protection based limited liability companies (LLC’s) and limited partnerships.  Formation of irrevocable asset protection and spendthrift trusts.  Evaluation of liability insurance and third party indemnity agreements.  Personal residence protection planning.  Review, evaluation and structuring of gifting, split ownership, insurance, limited liability company, limited partnership, domestic asset protection trusts, offshore asset protection trusts, ERISA and retirement plan protections. 
Real estate planning and tax strategies for investment, purchase, sale, rental and development. Creation of limited liability companies, limited partnerships and real estate joint ventures.  Formation of limited liability company, limited partnership and parent and holding company structures for investment and rental real estate.  Evaluation, counseling and planning for real estate sale and capital gains tax using charitable remainder trusts (CRT’s), IRC 1031 deferred like kind exchanges, installment sales, and other deferral techniques. Drafting of installment sale contracts, lease options, purchase contracts, and commercial and residential leases.
Business organization, incorporation, evaluation, planning, and formation. Formation of C-corporations, S-corporations, limited liability companies, limited partnerships, foundations and non-profit organizations in all U.S. States and foreign jurisdictions.  Preparation of employment contracts, buy-sell agreements, stock redemption plans, profit sharing plans, mergers and acquisition analysis, liquidations, shareholder and director meetings.  Mergers and acquisitions of closely held companies, stock purchase agreements, asset purchase agreements, licensing agreements, buy-sell agreements, contracts for services, contracts for sale, consulting agreements, indemnification and hold harmless agreements, purchase and sale agreements, lease agreements, and mutual release agreements. Tax planning and counseling are coordinated with the transactional services.
Estate Planning Services
Corporate Business & Tax Law Services
Pension and Benefits Services
Real Estate
Services
Legal representation of corporations, partnerships and individuals before the IRS, Franchise Tax Board, and other governmental agencies.  Areas of tax representation include:
•individual income tax,
•corporate and business tax,
•partnership tax,
•real estate tax,
•estate and gift taxes, and
•state and local taxation.

Representation of taxpayers in IRS and state income tax audits, appeals protests, agency hearings, offers in compromise, installment agreements.  Representation of taxpayers in pension and benefits audits and determination letters.  Representation of taxpayers in IRS or state tax collection proceedings, Collection Due Process Hearings, Innocent Spouse Relief, and related matters.  Legal and courtroom representation of taxpayer’s in the:
•United States Tax Court,
•United States District Court,
•United States Appellate Courts,
•United States Court of Federal Claims, and
•state courts. 


Asset Protection Services
Legal representation of tax professionals including accountants, enrolled agents, attorneys and other professionals in IRS investigations, promoter actions, tax shelter actions and tax return preparer penalties.   Legal representation and defense of CPA’s, enrolled agents, lawyers and other tax preparers against IRS tax shelter promoter investigations and penalty assessments.  Legal representation of tax professionals before the Department of the Treasury Office of Professional Responsibility.  Defense of IRS penalty claims under IRC 6662, 6700, 6701, and similar statutes.  Representation of tax professionals in IRS summons matters, attorney client privilege, and accountant privilege matters.

Taxpayer Representation
Legal representation of taxpayers under IRS, federal or state taxing agency audit.  Forensic accounting review, analysis and support of company, partnership, individual and pension plans under audit.  Forensic actuarial review and defense of pension plans under audit.  Preparation and filing of taxpayer Protests to IRS Appeals.   Processing of Freedom of Information Act (FOIA) requests to obtain records of governmental agencies to include the IRS. 

For more on information on the Tax Controversy Process and your representation in pre-controversy, audit, appeals and court, select the link to Tax Controversy Process.
Representation of Tax Preparers and Professionals
Legal representation and defense of specialized tax shelter promotions.  Defense and legal representation associated with IRS listed transactions, reportable transactions and transactions of interest.  Specialized plan defense for 412i Defined Benefit Pension Plans, 419 Welfare Benefit Plans, Employee Stock Ownership Plans, international tax transactions, certain Roth transactions, and VEBA plans. 

Tax Audit and Appeals
Tax Shelter, Listed Transactions & Reportable Transactions Defense
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"SAVE TAXES, PROTECT ASSETS, AND PRESERVE WEALTH"