Taxation

Tax decisions affect nearly every industry, presenting challenges and risks to individuals, privately-held businesses, and public companies alike. Whether you own an established business or
nonprofit organization,
work for a government agency, or handle domestic and cross-border transactions, Dickinson Wright’s Taxation practice offers innovative and comprehensive services to assist you in navigating complex tax laws.

As a full-service law firm with
offices
across the U.S. and Canada, we work seamlessly cross-border on U.S. federal, state, and local tax matters, as well as Canadian federal, provincial, and local tax matters.

Our Services

Core Tax Services

Transactional Tax

• Partnership formation, capitalization, acquisitions, dispositions, and related transactional matters
• Tax-free corporate reorganizations, recapitalizations, and restructurings
• Tax consequences of buying or selling a business or its assets
• Tax planning for distributions, redemptions, and owner buyouts
• Tax matters associated with private equity fund formation
• Tax matters related to portfolio investment acquisitions and dispositions
• Federal tax aspects of real estate financing and development
• Tax-advantaged financing structures including tax-exempt bonds, New Market Tax Credits, historic rehabilitation credits, and low-income housing credits

State and Local Tax

• Advising on state and local tax implications of mergers, acquisitions, and asset purchases
• Successor liability analysis for tax obligations
• Voluntary disclosure agreements to reduce penalties and liabilities
• Refund recovery for overpaid sales and use taxes
• Transaction privilege tax guidance for developers and contractors
• Tax incentives and compliance for data centers and renewable energy projects
• Property tax exemption counseling for nonprofit organizations

International Tax

• Application of U.S. bilateral tax treaties
• Customs and excise tax matters
• Inbound and outbound cross-border investments between Canada and the U.S.
• Joint venture structures involving U.S. and Canadian entities

Tax-Exempt Organizations

• Formation of tax-exempt organizations
• IRS recognition of tax-exempt status
• Federal tax compliance counseling
• Private foundation operations
• Joint ventures involving exempt organizations
• Unrelated Business Income Tax (UBIT) compliance

Tax Controversy

• Representation in IRS, Revenue Canada, and state/provincial/local tax audits
• Tax litigation involving assessment, valuation, and classification disputes

Representative Case Matters

• Tax counsel to companies across multiple industry sectors, including technology, real estate, charter school management, manufacturing, distribution, retail, financial services, insurance, legal, healthcare, and others.
• Counsel to closely held and public companies in federal tax matters, including tax-free corporate reorganizations, mergers, acquisitions, divestitures, and joint ventures.
• Served as tax counsel to issuers of billions of dollars of tax-exempt bonds, including governmental bonds, private activity bonds, qualified 501(c)(3) bonds, and exempt facility bonds.
• Advised developers, nonprofit, for-profit, and governmental entities on more than $100 million of tax-advantaged financings and economic development incentives, including New Market Tax Credits, Historic Rehabilitation Credits, and other federal and state tax incentive programs.
• Provided counsel to private equity funds on fund formation and tax matters, with an emphasis on federal partnership taxation issues.
• Advised individual and business clients on investment and business transactions to minimize tax exposure and ensure compliance with applicable tax laws.
• Counseled clients on entity formation, choice of entity, and related structuring considerations.
• Represented small to multinational businesses in federal and state tax controversies, including tax appeals and refund litigation.
• Represented manufacturing and industrial property owners in reducing ad valorem tax liabilities by millions of dollars.
• Advised multistate multilevel marketing companies on sales and use tax nexus issues.