All companies, organizations and individuals can expect to encounter tax issues. In order to provide our clients with the experience and services they need, Polsinelli Tax attorneys must have either a Master’s in Accounting, be a CPA or have a Master’s in Tax Law. With those qualifications, Polsinelli Tax practice attorneys provide creative solutions and legal guidance on international, federal, state and local tax laws to entities in all major industries and tax status classifications. Our attorneys partner with clients to develop business solutions related to:

Polsinelli Tax practice attorneys’ strong reputation is built on sound and effective planning, in-depth analysis and favorable resolutions and outcomes, particularly in complex tax matters involving diverse businesses. We are innovative and have vast experience in structuring business formation, combinations, reorganizations, mergers and acquisitions, and liquidations in the most tax-advantageous manner. If needed, the Polsinelli Tax Practice attorneys’ litigation experience spans all judicial forums, including the U.S. Tax Court, federal courts, state courts and administrative tribunals throughout the country. 

Polsinelli Tax Practice attorneys’ experience and sound judgment provide clients with appropriately assessed tax risks with the potential benefits of a judicial or administrative resolution of the issue. Polsinelli Tax attorneys bring both Certified Public Accountant (CPA) and advanced legal qualifications to tax advising (including LLMs) for individuals and businesses. Offering both extensive tax planning and tax audit and appeal services, we represent our clients’ interests in preserving income and protecting assets.

With offices located coast-to-coast, Polsinelli’s Tax attorneys are also equipped to represent clients regarding local, county and state tax issues for employment and independent contracting, partnerships and LLC structuring, audits and tax controversies across the United States. The Polsinelli Tax practice is experienced in handling the following issues:

  • Income tax
  • Sales and use tax
  • Excise tax
  • Property tax

Our team is well-versed in all kinds of tax controversies that can arise and we are prepared to take appeals to state tax appeal tribunals and appellate courts. Clients who work with us know that our Tax attorneys are skilled at communicating highly technical areas of the law, making it easy for clients to understand. This talent sets us apart from many of the professionals practicing in the tax industry.

Publications
90 Days, 10%: IRS Opens New Easement Settlement Window
Key Takeaways: The IRS has opened a limited settlement window for eligible conservation and historic preservation easement disputes, with a reduced 10% gross valuation misstatement penalty available during the first 90 days. The initiative applies only to partnerships that receive individualized settlement letters from the IRS. The new program offers substantially more favorable terms than the 40% penalty the IRS has frequently pursued in syndicated easement litigation. Partnerships that miss the initial 90-day window may face a higher 20% penalty and less favorable settlement treatment after 135 days. Partnerships, investors and representatives should review any IRS settlement correspondence promptly and evaluate whether participation makes sense under the circumstances. The IRS has announced a new time-limited settlement opportunity for eligible conservation easement and historic preservation
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IRS Opens the Door on Syndicated Easement Settlements: Limited Time Offers Coming
Key Takeaways The IRS announced it will soon release settlement terms for certain syndicated conservation and historic preservation easement disputes under Section 170(h). The initiative is expected to provide a limited-time opportunity to resolve pending matters with greater tax certainty. The settlement initiative signals a continued IRS enforcement focus on syndicated easement transactions despite offering a potential path to resolution. Recent Tax Court decisions continue to reflect close scrutiny of valuation positions, technical compliance and penalties. Partnerships and investors should begin reviewing procedural posture, governance requirements and supporting documentation before settlement offers are issued. Early preparation may be important because the IRS is expected to provide a limited response window. In a May 6 announcement, the Internal Revenue Service (IRS) stated it will soon
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