Our attorneys work closely with clients and their accountants to plan for transactions, business activities and mergers and acquisitions so they can be executed in a tax efficient manner.   Our services don’t stop there, once a plan is implemented, we provide the client advice in the areas of tax review, compliance, reporting and controversy.  We provide services to clients ranging from large multinational corporations to small startups.  The following is a representation of the type of projects we have recently handled:

• Advised clients on the benefits and limitations of operating potential operations in the form of a c-corporation for U.S. income tax purposes.
• Advised businesses on how to structure transactions for the acquisition of stock and assets in the most tax efficient manner.
• Structured, negotiated and drafted the requisite agreements for Merger and Acquisition purposes.
• Conducted internal reorganizations to streamline the number of operating companies in the United States.
• Provided clients with planning to maximize the benefits of existing net operating losses.
• Assisted clientele in the preparation of complicated U.S. consolidated income tax returns.
• Managed the IRS and State income tax audit process.
• Drafted and secured Private Letter Rulings for clients and the related state level rulings.

We are always monitoring changes in tax law to discover new opportunities for our clients.  For example, United States domestic tax laws involving U.S. Corporate Taxpayers have changed significantly since the 2017 Tax Cut and Jobs Act. The United States is no longer considered one of the highest taxing jurisdictions in the world. The changes have made the U.S. Corporate Tax structure much more appealing in terms of structuring.  A sampling of some of the recent federal tax changes that affect or have affected such companies includes:

• Corporate Tax Rate Reduction to 21%.
• Alternative Minimum Tax Repeal.
• New Limitations on the Deductibility of Interest Expense.
• Changes to Corporate Net Operating Losses.
• Bonus Depreciation and Full Expensing.

Additionally, US state and local tax laws in varying degrees conform (or do not conform) with the foregoing federal laws adding further to the challenges to any U.S. Corporate tax planning and compliance. State and local governments are facing increasing budget pressures leading to more audits and scrutiny of taxpayer positions.  And the US federal tax laws are still evolving through ongoing regulation, rulemaking, and court decisions.

Culhane Meadows brings a team of experienced tax law partners working in various areas of tax law to help each client plan for and comply with the U.S. corporate tax laws that may be applicable to the client’s situation. Our partners work to keep current with tax law changes through ongoing study.

We look forward to hearing from you with your tax compliance and planning questions to see if we can be of service to you. Below is some additional information about our U.S. corporate tax practice.