Tax

Tax


Rampart Law Group tax lawyers have extensive experience in all aspects of state and federal tax law. Our attorneys provide a full complement of services in virtually all types of tax matters for individuals, businesses both large and small, and charitable and tax-exempt organizations.

We provide sophisticated tax planning advice to both local individuals and organizations. We also represent out-of-state companies with local tax problems, often negotiating favorable settlements and working to avoid adverse tax consequences. We work with the managers, accountants and in-house counsel of companies to resolve a variety of tax-related issues, including business formation, compensation and benefit plans, acquisitions and financing.

In addition to tax planning and structured transactions, Rampart Law Group's tax practice includes representation before the IRS and the state tax authorities, Federal and State tax courts, and various other local tax authorities. One significant advantage in using a tax attorney to resolve disputes, instead of your accountant, is that a typical conversation with an accountant is not privileged, and may be disclosed in litigation or subpoenaed by the IRS or other tax authorities. Tax attorney communications are treated as confidential, attorney-client privileged communications. It is important to have a competent, reliable attorney deal with the federal, state and local tax authorities.

Business Tax Matters

Rampart Law Group attorneys counsel businesses on a wide range of matters, including: choice of entity matters, tax planning matters, business audit matters, and all tax aspects involved in the acquisition and disposition of a business. It is important to address tax implications in selecting the type of business entity and to understand the difference between state classification of entities and tax classification of entities. We work directly with the owners to analyze their needs and ensure that the business has the right state and tax classification. Good tax planning can minimize the impact of corporate business tax, income tax, self-employment tax, payroll taxes, and capital gains taxes.

Personal Tax Matters

Rampart Law Group attorneys counsel individuals on a wide-range of tax matters, including: the tax implications of estate planning and administration; negotiations with the IRS and other tax authorities; property tax liens; personal liability for business tax debts; and personal tax implications of business sales, purchases and succession.

Estate and Inheritance Tax Planning

Rampart Law Group attorneys bring experience generational wealth planning, advising on passing assets from one generation to the next, while paying the least amount of taxes required. There are many ways to structure an estate, using wills, trusts, insurance policies, and other agreements to ensure the lowest possible tax burden, and it is important to make the maximum legal use of them. However, there are many structures that require advance planning, without which much of the value of the structure is lost.

Property Tax Issues

Rampart Law Group tax lawyers assist residential and commercial property owners on a wide variety of property tax issues, such as property tax abatements and appeals, choosing the right entity to hold commercial or investment property to minimize tax burdens, farmland exemptions and 1031 like-kind exchanges.

Negotiations with Taxing Authorities

When facing actions by federal and state taxing authorities, it is important to have an experienced tax lawyer in your corner. Rampart Law Group tax attorneys are experienced in negotiating with the state taxing authorities and the Internal Revenue Service, and we have helped many taxpayers with what seemed to them like insurmountable problems. Examples of negotiations with the IRS and other taxing authorities handled by attorneys include negotiation of property tax liens, negotiation of liens for unpaid sales taxes, negotiation of "innocent spouse" liability, interest and tax penalty abatements, offers in compromise, and negotiation of payment plans.

Not-for-Profit Entities

We recognize that not-for-profit organizations are businesses with employees, contracts, leases and various assets and intellectual properties to protect. We draw on the experience of attorneys in other practice areas as needed to provide our clients with an approach to the various and unique legal issues in each representation.

Rampart Law Group represents tax exempt organization of all types, including charitable organizations, private foundations, trade associations, and public entities (including municipalities and public authorities) on a variety of regulatory and tax matters, ranging from entity formation to establishing and maintaining tax exempt status and, when appropriate, dissolution, including proper distribution of charitable assets and termination of exempt status.

As part of the entity formation for exempt organizations, we draft charters and by-laws or trust instruments with necessary and appropriate provisions tailored to their needs, including any special provisions as to voting and indemnification.

We understand and appreciate the tax considerations that are the backdrop for everyday operations of non-profit organizations. Accordingly, we can counsel clients as to how to operate consistently within their exempt status, including identification and avoidance of private inurement and excess benefit issues, how to proceed with advocacy efforts in the context of restrictions on lobbying and political activities, complying with state charities' registrations and fundraising regulations, and addressing charitable gaming licensure issues at the state and local levels. We are well-versed in review of transactions with disqualified persons, including assessment of potential excess benefit transactions and advising boards on following proper procedures to avail themselves of the rebuttable presumption under the intermediate sanctions regulations. We coordinate with accounting professionals in unrelated business income tax analyses and Form 990 completion and reporting issues.