Tax Law

Overview

The Tax Law Practice at Jackson & Campbell specializes in tax planning for all types of taxpayers, including non-profits, for-profit corporations, international business structures, estates and individuals. In addition, our attorneys represent clients before the Internal Revenue Service as well as state and local taxing jurisdictions, whether applying for recognition of exempt status; under civil examination; or subject to collection actions and liens/levies. Jackson & Campbell’s attorneys zealously represent clients before the IRS, and patiently work through the bureaucracy to reach the best solution for the client taxpayer. In addition, we work with clients to achieve the business structure that best satisfies the client’s business model and purpose, while minimizing the tax burden imposed, whether domestic or foreign. Our attorneys also keep abreast of current legislation and IRS guidance, in order to keep clients compliant and on the forefront of any new tax incentives.

Jackson & Campbell attorneys represent all types of taxpayers, including:

  • Large and small public charities
  • Private foundations
  • Associations and other nonprofits
  • Estates/Trusts
  • Healthcare entities
  • Small and mid-market businesses
  • Multi-national corporations
  • Individuals

Our attorneys regularly counsel clients in the following areas:

  • Tax planning to achieve tax efficiencies
    – International and/or Domestic issues
    – Impact of tax treaties
    – Potential off-shore tax savings
  • State and federal tax controversies/litigation
  • Employment tax issues
    – Independent contractor status
    – Compliance with required IRS Form filings
    – Payroll tax compliance
  • Resolving/abating employment tax civil penalties
  • Release of liens
  • Offers in Compromise
  • Mergers and acquisitions, including tax-free reorganizations
  • Like-kind transactions
  • Tax free exchanges
  • Energy tax credits
  • General tax compliance
  • Review of tax returns, including the new Form 990
  • Lobbying regulations
    – Section 501(h) elections
  • Estate and gift tax issues
    – Planning for grantor and non-grantor trusts
    – Planning with family limited partnerships
    – Planning to address the value of an estate, and minimize taxation
    – Planning and utilization of unified credit exemption amounts
  • Private foundation issues:
    – Avoid self-dealing
    – Avoid excess business holdings
    – Avoid taxable expenditures
    – Avoid jeopardy investments
    – Assist in maximizing qualifying distributions
    – Expenditure responsibility
    – Equivalency determinations
  • Public charity issues:
    – Unrelated business income tax
    – Joint ventures
    – Low income housing tax credits
    – Meeting the public support test
    – Maintaining exempt status
    – Compliance with Form 990 requirements
    – Reasonable compensation: Section 4958 rebuttable presumption
    – Pre-approval of scholarship and educational grant making programs

Representative Matters

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Blog Posts

  • August 2017
    Upcoming Event: How Women Lead

    How Women Lead Featuring Flora D. Darpino, 39th U.S. Army Judge Advocate General... Read More >

  • July 2017
    Charitable Conservation Easements

    RP Golf, LLC, lost its appeal and its claim of a $16.4 million charitable tax deduction for its donation of a conservation easement on its two golf courses.  On June 26, 2017, the Eighth Circuit affirmed the U.S. Tax Court’s opinion, holding that not all of the detailed requirements for charitable conservation easements had been complied with in a timely... Read More >

  • July 2017
    The United States as a Tax Haven for Non-Citizens:  QDOT’s to the Rescue

    Now that Switzerland and other off-shore locations are not as attractive to those wishing to safeguard their funds, the United States has emerged as a tax haven, of sorts, with several states providing friendly incentives for investors who are not U.S. citizens. However, foreign investors need to be aware of their potential liability for estate taxes.  U.S. property owned by... Read More >

  • February 2017
    Forgiven Debt – Taxable to the Borrower?

    Generally, if a borrower is required to pay a sum certain at a specific time, the obligation is considered “debt” under the Internal Revenue Code.  If the lender forgives a portion, it has “cancelled” the debt and the borrower must declare and take into income the dollar amount cancelled.  A lender may unilaterally decide that a debt is not collectable... Read More >

  • September 2016
    Tax Planning for Nonresident Aliens Who Own U.S. Property

    Individuals who are not citizens or residents of the United States, known as nonresident aliens (“NRA”), need to be aware of the United States estate and gift taxes that will be applicable to their U.S. fixed assets, for example, U.S. real estate.  If an NRA owns fixed assets located... Read More >