check out our TAX ADVICE & PLANNING
The quiet work that keeps a tax problem from ever happening.
Structure, transactions, and ongoing counsel for closely-held businesses, real estate investors, and high-net-worth individuals. The goal is simple: get the tax right before it becomes a dispute.
WHAT WE DO
Plain-English advice on complicated decisions.
Most tax problems we see in audit and Appeals could have been prevented at the transaction stage. Choice of entity, partnership agreements, basis tracking, accountable plans, reasonable compensation, transfer pricing, real estate elections — the answers are not always obvious, and the cost of the wrong one shows up years later.
We work alongside clients and their CPAs to make the decision well the first time, and to document it the way the IRS will eventually want to see it documented.
Matters we handle
- Entity selection and reorganization (LLC, S-corp, C-corp, partnership)
- Partnership and LLC operating agreement review
- Real estate transactions, 1031 exchanges, and passive activity planning
- Mergers, acquisitions, and business sales
- Reasonable compensation and accountable plans
- Cross-border tax planning, FBAR, and FATCA compliance
- Estate, gift, and trust tax planning
- IRS opinion letters and private letter ruling requests
Frequently Asked
Frequently Asked Questions
What is the difference between tax advice and tax preparation?
Tax preparation reports what already happened. Tax advice shapes what is about to happen — structuring a transaction, choosing an entity, planning a sale, or evaluating an investment so the tax result is intentional rather than accidental.
When should I get tax advice from an attorney instead of a CPA?
Bring an attorney in when the issue involves legal interpretation — complex transactions, novel structures, significant tax exposure, attorney-client privilege concerns, or anything that could turn into a dispute. CPAs and attorneys often work together; we collaborate with your existing tax preparer rather than replace them.
Can I rely on a tax opinion to avoid penalties?
A well-supported written opinion from a qualified tax attorney can establish reasonable cause and good faith, which is a defense to many penalties. The opinion must meet substantive standards — not every memo qualifies. We write opinions designed to satisfy those standards.
Are conversations with you protected by attorney-client privilege?
Yes, communications with us in our capacity as your attorney are protected by attorney-client privilege — a stronger and broader protection than the limited federal tax practitioner privilege that applies to CPAs and enrolled agents.
Do you provide ongoing tax planning or only one-off advice?
Both. Some clients engage us for a single transaction or question; others work with us on an ongoing basis as their tax counsel — reviewing structures annually, advising on new ventures, and coordinating with their accounting team.
What kinds of tax matters do you advise on?
Business formation and restructuring, partnership and S-corp planning, real estate transactions, executive compensation, tax-efficient sales and exits, IRS audit positioning, and complex individual matters. If it involves federal or state tax exposure, we can advise on it.
Have a transaction or decision on the horizon?
Schedule a call. We will tell you whether the question is one we can help with — and what good planning looks like for your situation.