Our tax attorneys provide tax advice to clients on a wide array of federal, state and local tax matters. With eleven offices located in Montana, North Dakota, and Wyoming, our tax attorneys are well positioned to assist a broad spectrum of clients with the complex and ever-changing tax laws.
Our tax attorneys have an extensive range of knowledge, expertise and experience to assist clients in navigating the hyper-complex web of federal, state and local tax laws through innovative, practical and efficient solutions. Many of our tax attorneys hold accounting degrees or advanced tax degrees. A number of our tax attorneys are also certified public accountants. Our tax attorneys have gained considerable experience in government, and private practice.
We draw on our extensive tax resources to provide tax solutions for our clients. We also foster a collaborative culture within our firm and encourage a coordinated team approach with our client’s accountants and other advisors to deliver efficient, practical and effective results for each client’s tax matter.
Tax laws affect virtually every aspect of business, from formation to dissolution. Our tax attorneys have extensive experience in advising clients on the tax aspects of limited liability companies, partnerships, corporations and other business entities throughout the entire life cycle of the entity. Our tax attorneys regularly advise clients on tax matters affecting business entities, including formation and capitalization, operations, governance, succession planning, recapitalizations and restructurings, debt financing, and liquidations and dissolutions.
Mergers and Acquisitions, Spin-Offs, and Reorganizations
Our tax attorneys advise clients on the tax aspects of mergers and acquisitions, spin-offs and other dispositions, reorganizations and restructurings, debt financing, and joint ventures. Tax considerations represent a critical component in determining the structure of a contemplated transaction. Our tax attorneys have extensive tax knowledge and experience to offer clients thoughtful and sophisticated tax advice relating to these transactions. Our tax attorneys also work with attorneys in our other practice groups to form multi-disciplinary teams when appropriate to provide comprehensive, value-adding and efficient legal advice to guide clients through complex transactions.
Natural Resource and Energy Taxes
Our tax attorneys have a long tradition of representing multiple segments of the energy industry with their federal, state and local tax matters, including tax issues relating to production, extraction and severance, gathering and transmission, pipelines, refining, and distribution. We also advise clients in the energy industry on tax incentives, acquisition and sales, and lobbying and compliance.
Nonprofit and Tax-Exempt Organizations
Our tax attorneys counsel nonprofit and tax-exempt organizations about the complicated interplay between the different federal and state agencies that regulate the activities of these organizations. We assist clients in the formation of nonprofit corporations, and represent nonprofit corporations in securing recognition of exemption from federal and state income tax. We advise tax-exempt organizations on all aspects of federal tax issues associated with their operations including, joint ventures with both nonprofit or for-profit entities, unrelated business income issues, and merger or consolidation of tax-exempt organizations. Our attorneys also assist nonprofit organizations in establishing effective employee benefit plans, developing related subsidiary organizations and creating efficient administrative procedures and governance policies.
Real Estate Transactions
Whether large or small, real estate transactions raise important tax considerations for clients. Our tax attorneys are experienced in advising clients on the tax aspects of real estate transactions, including farm and ranch transactions, Section 1031 like-kind exchanges, installment sales, subdivisions, real estate workouts and restructurings, real estate entity structures and transactions, and foreign investments in U.S. real estate.
State and Local Taxes
With a strong footprint in Montana, North Dakota, and Wyoming and considerable state and local tax experience at virtually all levels of state and local government, our tax attorneys are uniquely qualified to represent clients on matters involving state and local taxes, including income taxes and apportionment, employment taxes, property taxes, natural resource production, extraction and severance taxes, sales and use taxes, and excise taxes.
Our tax attorneys regularly assist clients with state and local tax planning and compliance to minimize state and local taxes. Our tax attorneys also advise clients on state and local tax incentives and credits and obtain advance state and local tax rulings.
In addition, our attorneys lobby legislatures and administrative agencies on state and local tax issues affecting our clients. Our tax attorneys negotiate with state and local taxing authorities to resolve client tax controversies and represent clients on tax matters before all levels of state and local administrative appeal boards, agencies and courts in our region.
Our tax attorneys have particularly specialized experience in property tax controversies involving major industrial facilities (such as refineries, processing plants, pipelines and equipment).
Tax Audits and Controversies
Our tax attorneys regularly represent taxpayers in all phases of tax audits and controversies with the IRS and state and local taxing authorities in Montana, North Dakota and Wyoming. We frequently represent taxpayers before state and local tax administrative bodies and courts.
Our tax attorneys also represent clients on federal tax audits and controversies with the IRS at all stages of the process, including IRS audits, administrative appeals and litigation before the U.S. Tax Court and U.S. Federal District Courts. We also advise clients regarding tax liens and assist clients with negotiating offers in compromise, installment payment plans and tax resolutions with the IRS and state and local taxing authorities.
Our tax attorneys have particularly specialized experience in property tax controversies involving major industrial facilities (such as refineries, processing plants, pipelines and equipment) and natural resource production, extraction and severance taxes.
Wealth Transfer Taxes
Our tax attorneys are experienced in estate and succession planning and trust and estate administration. Wealth transfer taxes (estate taxes and generation-skipping transfer (GST) taxes) and income taxes significantly affect planning and administration matters. The interplay among these types of taxes can be complicated. Our tax attorneys possess the expertise and experience to guide clients through the maze of wealth transfer taxes and income taxes in developing effective estate and succession plans and administering trusts and estates as efficiently as possible.