Butzel Long PC
Tax Law Practice
Virtually every transaction, from a simple charitable contribution to a multi-national corporate reorganization, has some tax consequences associated with its planning and execution. The tax attorneys of Butzel Long have a broad range of tax experience and expertise in all the areas of federal, state and local taxation, and work closely with attorneys in the firmÂ’s various other practice groups to maximize the tax benefits for our clients. This expertise was enhanced in June, 2006, by the addition of several lawyers from a premier tax boutique law firm. Butzel Long tax attorneys have advised clients ranging from wealthy individuals to multi-national Fortune 500 corporations.
Business Structure and Commercial Transactions
Butzel Long's tax attorneys provide advice on each step of a business's evolution, from the choice of entity on formation, through taxable and nontaxable acquisitions and divestitures, to termination of the business through sale or liquidation. In addition to changes in the business organization, our attorneys work to achieve the most tax-advantaged structure for other transactions involving such issues as capital changes through debt or equity issuances, recapitalizations and redemptions, financing alternatives, ownership transition of family-owned businesses, leasing, licensing, and day-to-day business operations. Our tax planning expertise includes advice not only on the effect of the transaction to the business and its equity interests, but also on how the transaction may affect future strategy and operations. A significant portion of the tax planning practice involves maximizing the tax benefits of proposed acquisitions, dispositions and reorganizations of businesses and business units.
Real Estate
The unique needs of real estate investors and the singular treatment accorded to real estate by the tax law are an area of specific focus for the firm. Our attorneys are regularly involved in establishing joint ventures, either in the form of partnerships or limited liability companies, for the acquisition, development, operation and disposal of real estate, while optimizing the allocation of tax benefits to the investors. The firm has represented both closely-held and publicly-offered real estate investments, including REITs. Deferring tax on appreciated real estate through deferred like-kind exchange mechanisms is a significant part of this practice.
International
The exponential growth of global trade has made international tax planning an integral part of the Butzel Long tax practice. Our representation includes both foreign investment in the U.S. and U.S. investment overseas. Our foreign clients, both individuals and businesses, have looked to us for advice on structuring their U.S. operations and the most tax-efficient manner of repatriating their U.S. earnings in conjunction with the U.S. tax treaty network. For our U.S. clients, we have structured their operations in a way that maximizes both the deferral of overseas earnings and the availability of the foreign tax credit to prevent double taxation. In addition, we have also advised our clients on matters as diverse as related party transfer pricing, the use of tax haven jurisdictions, foreign currency transactions, foreign sales corporations, and cross-border financing and leasing techniques, all of which are specifically tailored to the client's needs to minimize both the U.S. and foreign tax burdens of multi-jurisdictional taxpayers. Our membership in Lex Mundi, a global association of 140 independent law firms, allows us to coordinate the interaction of both U.S. and foreign tax laws for optimal benefit.
Compensation Planning
The firm has a significant amount of expertise in all areas of compensation planning. We have advised both private and publicly-owned companies regarding the development and compliance requirements (involving both tax and securities laws) of qualified and non-qualified retirement and deferred compensation plans, stock option plans, "golden parachute" payments, comprehensive "omnibus" compensation plans, union pension plan withdrawal liability issues, the creation of employee stock option plans (ESOP'S), and independent contractor and employee status matters.
Tax-Exempt Organizations and Bond Financing
Our tax-exempt organization client roster runs the gamut from private foundations to trade associations and other non-charitable, tax-exempt entities to large, publicly-supported charitable institutions. Butzel Long has represented numerous clients in obtaining and maintaining their tax-exempt status during a period of recent heightened government scrutiny and the enactment of intermediate sanctions requiring the ongoing review of transactions to ensure continuation of tax-exempt status. We have advised tax-exempt clients regarding the structuring transactions to preclude unrelated business income taxation.
The rapidly changing health care field raises numerous issues regarding excise taxes, unrelated business tax and continuation of tax-exempt status. We represent several clients in this field, including health care facility operators such as hospitals and nursing homes, in restructurings and affiliations with both for profit and non-profit entities. As part of our full service to tax-exempt clients, we also represent them in obtaining tax-exempt debt financing in both the public and private markets.
Estate and Individual Tax Planning
The tax law practice of Butzel Long includes a group of attorneys who have specialized in the areas of individual financial and estate tax planning. The practice involves the development of sophisticated estate plans which provide for the orderly transition of family-owned businesses, lifetime gifts, charitable gift planning, minimizing overall gift and estate taxes, liquidity, and overall lifetime financial and tax planning. The financial and estate planning may include family limited partnerships, charitable remainder trusts, other retained interest property transfers, private annuities, tax advantaged investments, and family business ownership restructuring. Butzel Long's tax attorneys advise clients who reside for parts of the year in different states included capabilities with respect to applicable Florida law. The firm's attorneys also provide administrative and compliance assistance for the maintenance of family trusts.
Tax Controversy
Our tax controversy practice includes representation before the Internal Revenue Service and state and local administrative authorities and tribunals. On behalf of our clients, we have obtained private rulings and advisory opinions to confirm the tax consequences of a transaction prior to consummation. Our client advocacy practice includes representation during audits and administrative appeals, obtaining technical advice as to the correctness of the taxpayers position, and litigation of the taxpayer's position before the U.S. Tax Court, Court of Federal Claims, U.S. District and Circuit courts, and state courts.
State and Local Taxation
In regard to the recent political trend the increasing revenue demands of state and local tax jurisdictions, we have focused on multi-jurisdictional tax planning, including structuring transactions and operations in a manner that minimizes the clients' exposure to state and local tax regimes, including income tax, franchise tax, sales and use tax, property tax, realty transfer tax and intangibles tax. In addition, we can advise clients on unique features of the Michigan Single Business Tax.
Tax and Economic Incentives Practice
Operating a successful and profitable business in today's global economy can be challenging. Labor and other operating costs in various geographic regions as well as outside the United States continue to impact the cost structure for U.S. based manufacturers. As a result, tax incentives, government grants and business credits play an increasingly important role in planning new developments and reinvestment projects. State and local governments around the world recognize this fact and have embraced, and in some cases championed, the idea of offering aggressive tax credit and creative incentives, and financing programs to potential investors and businesses in order to win the "site location lottery". Federal, state and local grants can assist existing business seeking to expand their operations.
At Butzel Long, our team of professionals can help clients weave through and decipher the wide variety of government programs designed to help reduce the cost of new investment and operations. These programs often have stringent qualifications that our professionals can quickly understand and interpret. When tax exempt or public bond financing is involved, Butzel Long's public finance attorneys are the top in their profession providing thorough advice to clients. When infrastructure development is involved, Butzel Long's real estate attorneys are knowledgeable resources. Our team can assist companies in applying for a myriad of state and federal grants.
The firm's government relations initiative, BL Government Affairs (BLGA), was established to play a critical role in helping our clients "shepard" a project through the government process. BLGA can evaluate existing statutory and regulatory conditions and provide sound advice and where appropriate advocate change and improvement in government regulations. The relationships and resumes of the professionals leading the efforts at Butzel Long and BLGA provide a unique advantage to clients.
Other relationships with complementary support services can also play a role in a successful development. Butzel Long maintains strong relationships with groups such as marketing and public relations firms, professional and chamber based business organizations, and local economic development organizations. Knowing who to call and being able to access and utilize these important support services on behalf of the needs of specific clients are key components of the practice group.
Our record of success in helping clients obtain the most beneficial incentive packages for which they are qualified confirms the effectiveness of our team and our approach. Our work ranges from multi-party international manufacturing ventures to green field developments to complex urban real estate redevelopment projects. Examples include the $180 million redevelopment of the Westin Book Cadillac Hotel and residences in downtown Detroit with over 17 different layers of financing and tax credits to the Global Engine Alliance, LLC, which represents one of the largest investment related tax incentives in the State of Michigan for its engine manufacturing facility , to the formation of 4 Tool and Die Collaborative representing over 60 tool and die companies providing state and local tax incentives that have helped save that industry in Michigan. For many of these projects, their economic feasibility was dependent upon the creative and focused efforts of our team to identify and negotiate favorable incentive packages.
Our cross-disciplinary approach combines the expertise of top legal, economic development and government relations professionals and provides broad based solutions to the needs of clients. The value proposition that we can provide to businesses seeking to grow profitability in a competitive environment can be measured in their bottom line results.
Butzel Long PC
150 W Jefferson Ave #100
Detroit MI 48226-4450
Tel: 313 225-7000
Fax: 313 225-7080
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