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.

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Preparing Tax-Exempt Organizations for the New Covered Employee Rules for the Expanded Code §4960 Excise Tax
Key Takeaways: The OBBBA significantly expanded Code §4960 for taxable years beginning after Dec. 31, 2025, broadening the scope of employees that tax-exempt organizations must evaluate for potential excise tax exposure. The definition of “covered employee” for tax-exempt organizations now covers any employee of a tax-exempt organization who receives remuneration exceeding $1 million or an excess parachute payment during the applicable taxable year — extending Code §4960 beyond the prior focus on an organization's five highest-compensated employees. Tax-exempt organizations should review compensation arrangements, deferred compensation plans and compliance processes before the new rules take effect, particularly where compensation may approach or exceed the $1 million threshold. The One Big Beautiful Bill Act (OBBBA) amended Code §4960, which imposes an excise tax on certain excess
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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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