Since taxation is such a formidable part of our practice often integrated with many other areas, the Firm devotes considerable amounts of its time to its Taxation & Audit, Tax Appeals & Litigation practice.  It is a natural adjunct to the Estate Planning, Estate Administration, Corporate, Acquisition and Finance practice:

Estate and Gift Taxes
The Firm prepares the Federal Estate Tax Return and all accompanying schedules and documents after making a due diligence review of the details of all the Schedules and includible assets.  The Estate Tax Return is an integral part of estate administration and, importantly, deals with complex estate tax includability issues under the Internal Revenue Code.  Detailed Analyses are made of the many complex includibility areas. Inasmuch as planning focuses on the same issues, this estate tax includability under the intricate IRC rules is an overriding concern at the inception, on the preparation of the tax returns and, notably, on audit.  In addition, the New York State and other state estate tax returns are prepared.

The Federal Gift Tax Return Form 709 is closely coordinated with the estate accountant who ultimately prepares and files the final Gift Tax Return.

Other Tax Matters
Frequently, capital gains and coordinating income taxes with the Estate Accountant is an important part of the preparation of estate and gift tax returns.

A determination is made with the estate accountant as to the utilization of expenses on the estate versus the estate income tax returns.  Consideration is given to utilization of excess carryover losses in the estate by the beneficiaries and Distributable Net Income issues relating to distributions.

Audit
The Firm has conducted numerous, complex and substantial estate and gift tax audits and proposed substantial assessments; often being referred by fiduciaries, accountants and attorneys.  It has successfully completed audits, defending major discounts, includibility items, prior gifts, values and substantial business areas of exposure.  It has also successfully used installment payments under several sections of the Internal Revenue Code.

Appeals and Litigation

The Firm has actively conducted appeals within the Internal Revenue Service as well as Tax Court Petitions, negotiations and litigation.  It has handled enforcement proceedings, Voluntary Disclosure and Trust Fund Liability with respect to withholding taxes, as well as the negotiations thereon.

Residency Issues
The Firm has been involved in numerous residency issues involving the application of income and estate taxes and has, as part of its planning, addressed these issues, particularly with Florida residents.

Acquisitions, Shelters and Investments

Analysis, structuring, tax effect, sale, allocation, adjustments, recapture, Earn outs, documents, letter of intent, definitive agreement, etc.; private offering, exemption/audit; (see Corporate/Acquisition).

Income; State & Local; Foreign

Range of income tax planning integrating estate, business, pension/benefits; acquisitions and business arrangements/taxes; numerous state and local income, sales, gross receipts, excise, real estate and other taxes; foreign tax matters, treaties, credits and authority; including issues relating to inter-company pricing, offshore sourcing, allocation of values, repatriation, Trust/Fund Withholding Liability, foreign tax credits, treaties, etc. (see Corporate/Acquisitions).