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TAX CONTROVERSIES

Clients seek our help when faced with an audit by the Internal Revenue Service or the Arkansas Department of Finance and Administration, or where the IRS or state and local authorities are attempting to collect a tax assessment. Our broad experience covers income taxes, sales and use taxes, estate and gift taxes, excise taxes and ad valorem taxes. We also handle collection-related matters where the IRS or state is attempting to collect taxes. You will get an effective defense in audits, administrative hearings and proceedings, and appeals before the IRS and state and local taxing authorities. We are committed to analyze and help our clients properly resolve (including litigating, if necessary) their disputes with the taxing authorities.

Focused on Clients

  • Corporations
  • Large and small businesses
  • Limited liability companies
  • Other business organizations
  • Nonprofit organizations
  • Individuals

Focused on Services

Business Tax Planning - Choosing the right business entity form to minimize taxes is the foundation of business tax planning. Lawyers from our firm assisted in drafting the Arkansas Limited Liability Company Act (also called the Small Business Entity Pass-Through Act) in the 1990s, and we fully understand how provisions apply to your business needs. We help you evaluate whether a limited liability company (LLC), partnership (LLP), an S Corporation, C Corporation, or some other vehicle is the best way for you to meet your growth and financing needs while maximizing tax advantages, then help you create the appropriate management and organizational structure. You also get current advice on issues involving the exemptions from Arkansas taxes, ad valorem property taxes, and the various intangibles taxes and transfer taxes. We are always alert to creative entity variations that meet any business tax planning need.

Most business transactions have potentially adverse tax consequences if not properly structured, so we help business clients — including individuals who own businesses — structure transactions to maximize business and tax benefits and to avoid potential problems. If you are a company owner or chief executive, we offer you sophisticated solutions for complex tax challenges in structuring like-kind exchanges, tax-efficient real estate transactions, and tax-free reorganizations. That includes variations such as reverse like-kind exchanges.

State and Local Tax – As the leading tax law firm in Arkansas, we have an excellent reputation and working relationship with the Revenue Division of the Arkansas Department of Finance and Administration. Whether your concerns involve personal or business taxation, you benefit from the fact that lawyers from our firm have helped shape state tax law by working directly with administrative taxing officials on audit and other tax related matters, as well as with legislators and tax legislation.

State Audits and Appeals - Our tax practice in Arkansas is noteworthy for our ability to handle audits, appeals, collection matters, and civil tax litigation. Given our strong working relationships with state tax officials, we frequently can make the kind of direct contacts that get appropriate results to in connection with sales and use tax audits and disputes, as well as challenges to ad valorem property tax assessments. If you are a manufacturer seeking an exemption entitlement under the state’s laws applying to manufacture, we are experienced and can help.

Federal Audits and Appeals - At the federal level, you get the benefit of our experience and thorough familiarity with the procedures of the IRS to reduce proposed tax assessments, abate or waive penalties, obtain private letter rulings and other formal and informal advice, advise on IRS demands for documents and other information, and negotiate offers in compromise, lien releases, and payment plans, and other administrative solutions to your tax problems. With the leading employee benefits law practice in the state (encompassing work on more than 1,000 benefit plans), we excel at ensuring that your benefit plan provisions comply with IRS and Department of Labor tax regulations.

Estate and Gift Tax Controversies – We have proven success representing clients in tax controversies on estate and gift matters, including disagreements with tax authorities’ overvaluations, exemptions from taxation and other matters.

Tax Litigation – We have successfully litigated tax controversies before the U.S. Tax Court, Federal District Court, Eighth Circuit Court of Appeals and the state courts of Arkansas. When litigation is necessary, we engage our firm’s trial attorneys, who are recognized as among the best trial lawyers in the state to assist in handling the case.

Focused on our Team

With more than 30 attorneys and an impressive total of more than 700 years of experience, our tax attorneys focus on particular areas of the law to best serve our clients. Twenty-five of the firm’s tax attorneys have earned their Master of Laws in Taxation and many are inactive certified public accountants. Six attorneys have been selected as Fellows in the prestigious American College of Trust & Estate Counsel and the firm has the only two Arkansans who are Fellows of the American College of Tax Counsel. Our tax department also includes the only attorney in the state, and one of only 65 in the country, invited to be a member of the National Association of Property Tax Attorneys.

Friday, Eldredge & Clark holds seminars each year devoted to educating CPAs and business leaders on the most recent updates in tax law. Additionally, many of the firm’s attorneys participate in training seminars through the Arkansas State Chamber of Commerce, the Arkansas Society of Certified Public Accounts and other industry-related events.

 

 

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