The attorneys in Karr Tuttle Campbell’s Tax Practice Group provide representation in federal, state, local and international tax matters. We advise individuals and private and public business entities, including corporations, partnerships, limited liability companies and nonprofit organizations on a wide array of tax issues. We bring a high level of tax proficiency to client’s transactions and issues in order to develop creative solutions that minimize tax liabilities.
Attorneys in the Tax Practice Group have developed their proficiency through formal education and work experiences. Our tax attorneys hold advanced degrees in taxation and related disciplines such as accounting, and have practical prior business and accounting firm experience. Their skills have been sharpened over many years of engaging in tax planning, compliance and conflict resolution. As a result, the firm’s tax attorneys are able to bring a unique and practical set of skills to bear on client needs across the spectrum of tax law.
Some of the areas in which our tax attorneys have significant experience include:
Mergers & Acquisitions; Transactional Practice
The firm’s tax attorneys engage in tax planning for corporations and pass-through entities. This planning ranges from complex corporate mergers, acquisitions, reorganizations, redemptions, recapitalizations, stock offerings, debt financings and complete and partial liquidations, to planning appropriate business structures for start-up and medium-sized businesses. We have substantial experience in planning for maximizing the use of net operating losses in connection with changes in business ownership. We also assist clients by obtaining advance rulings from federal and state tax authorities on the tax consequences of specific transactions.
Real Estate Tax
Attorneys in the Tax Practice Group engage in planning for and analysis of tax issues in connection with investments in, holding, syndication and disposition of real estate. This includes drafting complicated partnership and LLC allocation and distribution provisions, and advising on the federal and state aspects of Section 1031 like-kind exchanges of fee interests and tenancies-in–common (TICs). We work with developers and syndicators of Section 42 low-income housing tax credit projects in analyzing, structuring and re-structuring these complex transactions.
State & Local Tax
Attorneys in the Tax Practice Group routinely deal with issues of state and local taxation for Washington State, City of Seattle, and other state and local jurisdictions. In Washington, we are experienced with nexus issues, business and occupation tax, sales and use taxes, real estate excise tax, and real property tax, and we engage in planning to minimize such taxes. We represent clients in applications for tax refunds, during tax audits, on administrative appeals of assessments, and in state court litigation with tax authorities. We also advise on the complex and frequently inconsistent multistate and constitutional income and excise tax issues faced by multistate businesses.
Non-Profit (Tax-Exempt) Organizations
We regularly advise tax-exempt charitable and educational organizations regarding the federal and state requirements for obtaining and maintaining their tax-exempt status, as well as addressing issues regarding unrelated business income tax (UBIT), prohibited transactions, and assisting with tax-exempt bond financings. We are also regularly involved in the organizational and operational activities of private foundations, including structuring to achieve charitable goals, forming the organizations, and preparing applications for tax exemption.
Attorneys in the Tax Practice Group have experience in advising clients on the tax aspects of international transactions under U.S. tax laws and tax treaties with foreign countries, including advice on inbound investments by foreign investors and outbound transfers by U.S. entities, issues arising under the Foreign Investment in Real Property Tax Act (FIRPTA) and other withholding tax requirements, and the taxation of non-resident aliens and foreign corporations under various circumstances. We work with U.S. exporters on the formation of Interest Charge Domestic International Sales Corporations (IC-DISC) to obtain the benefits of tax rate reduction that these entities provide on foreign sales.
The firm’s tax attorneys are often involved in representing client interests in dealing with the Internal Revenue Service and relevant state departments of revenue. Our attorneys have represented client interests at both the federal and state court level.