The manner in which a newly formed entity is taxed can have significant economic impact on that entity and its affiliates. A number of issues must be addressed pertaining to choosing the type of entity: C corporation, S corporation, general partnership, limited partnership, or limited liability company (and if such LLC will or should be taxed as a sole proprietorship, partnership, corporation, or disregarded entity). Polsinelli Tax attorneys have in-depth knowledge and experience in counseling and assisting clients with complete tax entity planning processes, including the more atypical/exotic entity forms (i.e., a cooperative, REIT, UPREIT, and REMIC).
In addition to tailoring specific tax considerations to each client, Polsinelli Tax attorneys discuss with clients the following items regarding possible tax advantages and/or disadvantages pertaining to the tax structure involved in their “choice of entity” decision:
Polsinelli Tax attorneys also assist and counsel clients with "mid-stream" changes in entity type (e.g., the incorporation of an LLC taxed as a partnership) and the possible tax implications of such changes.
Our State and Local Tax practice has considerable experience advising clients on a variety of state and local tax matters involving income, sales and use, inheritance and property taxes. This includes audits of taxpayers, appeals to administrative agencies, appeals to the courts, and judicial review of agency decisions. Polsinelli has litigated a number of state tax cases, including the following:
Income, Sales & Use Taxes: