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Introduction
Davis Wright Tremaine provides an extensive
range of tax law services to international, national, regional and
local clients. We represent numerous corporations, partnerships, limited
liability companies and individuals on a continuing basis. We also
offer tax advice in planning and structuring complex transactions.
Each member of the tax group has a background
in general corporate and tax matters and also concentrates in one
or more particular areas of tax law, including corporate, real estate
transactions and syndications, partnerships and limited liability
companies, state and local, exempt organizations, banking, international
and individual taxation.
Our lawyers are actively involved in activities
of the tax section of the American Bar Association and regularly
publish articles and speak on topics covering federal, state, and
international tax issues. Several members of the group are also
adjunct faculty in the LL.M. taxation program at the University
of Washington.
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Department Members
- Los Angeles
Marc E. Jacobowitz
- Portland
James F. Ambrose
Stuart Harris
Carmen J. SantaMaria
Erik Schimmelbusch
Garry J. Schnell
- Seattle
Brent R. Eller
Garry G. Fujita
Michael E. Gentile
Monica Gianni
Dirk J. Giseburt
C. J. Judson
Durham C. McCormick
Martin R. Morfeld
Michele C. Osborne
Susan Schalla
Brian Todd
Joseph M. Wallin
LaVerne Woods
James E. Wreggelsworth
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In the News
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Davis Wright Tremaine Partner James Wreggelsworth Named Chair of Partnerships and LLCS Committee of American Bar Association’s Section of Taxation [Dec. 2006] read more
Related
Links
- Deals &
Transactions
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Related Practice Areas
- Health Care
Real Estate & Land Use
Tax-Exempt
Organizations
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Range of Services Offered
Corporate
Transactions
Members of the Tax Section advise clients and participate in the negotiation
and documentation of a vast array of corporate business transactions,
many of which involve interstate and international tax and business
questions. These transactions include common and preferred stock offerings,
corporate mergers and other acquisitive and divisive corporate reorganizations,
recapitalizations, redemptions, and complete and partial liquidation
transactions. The Tax Section assists our clients in structuring and
documenting these transactions in a tax-effective manner, including
the drafting of definitive agreements and offering documents, issuance
of opinion letters, and applying for and receiving advance rulings
on the tax implications of the transaction.
Sale
Transactions and Succession Planning
Members of the Tax Section play an integral role in the structuring
and documentation of the purchase and sale of businesses to assist
our clients in achieving their business objectives while minimizing
the federal and state tax costs arising out of the transaction. Our
tax lawyers also advise clients regarding business succession strategies
with a focus on steps that facilitate the transfer of business ownership
to other family members, management groups and third-party purchasers
in a tax-effective manner.
Pass-Through
Entities
The Tax Section provides advice to our clients on a wide range of
tax issues in connection with the formation, operation, reorganization,
restructuring, and liquidation of pass-through entities such as general
and limited partnerships, limited liability companies, limited liability
partnerships and S corporations.
Real
Estate Transactions
The Tax Section works closely with the firm's Real Estate and Land
Use Department in advising our clients with respect to tax issues
in real estate matters and transactions. The Tax Section is involved
in the structuring and documentation of a variety of real estate transactions,
including both public and private real estate syndications, certified
rehabilitation projects, low-income housing projects, like-kind exchanges,
workout transactions, and other real estate matters.
State
and Local Taxation
Members of the Tax Section develop plans to help our clients minimize
their state, county and municipal tax obligations and represent clients
in tax controversies before state revenue departments. Our practice
areas include property and income taxes, gross receipts tax, real
estate excise tax, and sales and use tax. The firm has successfully
challenged the audit position of the Departments of Revenue of Washington,
Oregon, California, and other states. Members of the Tax Section have
assisted state legislatures on technical state and local tax matters,
including the drafting of proposed legislation. Members of the Tax
Section frequently testify or lobby before state legislatures for
clients with respect to tax matters.
International
Tax
The Tax Section represents a large number of companies and individuals
in international tax matters. These matters arise in the context of
foreign entities and individuals investing or engaging in business
in the United States, and United States entities or individuals with
international operations. The Tax Section regularly advises clients
on issues such as FIRPTA, cross-border withholding taxes, tax treaties,
foreign sales corporations, foreign tax credits, the branch profits
tax, international reorganizations and business acquisitions, transfer
pricing and U.S. taxation of income earned through foreign corporations.
Members of the Tax Section work closely with foreign attorneys and
accountants to provide complete tax and business advice to our clients.
Health
Care
Members of the Tax Section provide tax advice to taxable and tax-exempt
purchasers, payers and providers of health care services. For tax-exempt
health care organizations, members of the Tax-Exempt Organizations
Group provide advice on issues such as tax-exempt status, avoidance
of private inurement and intermediate sanctions, joint ventures with
physicians unrelated business income tax conversions to and from exempt
status, and executive compensation arrangements. Members of the Tax
Section have a close working relationship with the national office
of the IRS and are uniquely qualified to advise on issues of tax exemption
in the health care context.
Tax-Exempt Organizations
The Tax-Exempt Organizations (TEO) Group advises nonprofit organizations
and charitable donors on a full-time basis, bringing uniquely in-depth
knowledge in the areas of federal and state tax, and nonprofit corporate
and trust law. Members of the TEO Group advise on issues such as initial
qualification for exemption, avoiding private inurement and intermediate
sanctions, unrelated business income tax planning, private foundation
compliance, joint ventures with for-profits, conversions to and from
exempt status, venture philanthropy, cross-border giving, and tax
issues arising from Internet use. The TEO Group also regularly advises
nonprofit clients such as healthcare, long-term care, housing and
educational organizations on the issuance of tax-exempt bonds.
Venture Capital Financing
The Tax Section advises large and small clients about the tax aspects
of raising venture capital. In addition, the Tax Section has formed
venture capital partnerships and converted partnerships and limited
liability companies into corporations to facilitate initial public
offerings of stock or other venture capital financing. Equity-based
compensation plans are often an integral part of offerings and financing,
and our tax lawyers provide advice on how to structure such plans
so as to minimize income tax consequences.
Federal Tax Controversy
The Tax Section represents individual and institutional clients in
the resolution of federal tax controversies. The scope of representation
encompasses all phases of the tax assessment, collection, and litigation
processes, and members of the Tax Section have significant experience
in successfully litigating tax controversies.
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