TAX ADVISORY TAX SERVICES

Transcription

1 TAX ADVISORY TAX SERVICES

2 A Dedicated Team of Tax Professionals Today s economic challenges are forcing governments around the world to step-up tax enforcement in an effort to sustain revenue At the same time, companies are having to take a more proactive approach to minimizing their tax burdens in an effort to sustain both corporate revenue and shareholder value Gudorf Law Group s team of tax professionals understands your company s concerns and formulates tax strategies that are tailored around your company s goals and values We understand the concern for compliance, concern regarding corporate reputation, and the complexities of your industry as well as the global market We are a team of tax professionals that is dedicated to formulating long-term tax strategies that are backed with substantial legal authority We know the importance of details We listen to our clients We learn everything there is to know about each one of our clients We understand each one of our clients We are Gudorf Law Group

3 Gudorf Law Group s Tax Services Services Tailored to Your Goals and Values Our service philosophy is simple: we listen to, learn about, and understand everything there is to know about each one of our clients By looking at the world from the perspective of our clients, our team of talented and proven tax professionals are able to provide practical services and advice that are in sync with your business goals and values Combined with our real-world experience, technical know-how, and in-depth understanding of the law, we are able to provide unparalleled tax services and advice that far exceed the quality and scope of services provided by non-attorneys Among the services we offer are: Federal Tax Services Tax Controversy and Litigation International Corporate Services Mergers, Acquisitions, and Restructurings State and Local Tax Services Tax Exempt Organization Services Private Wealth Services What follows is a more in-depth look at the range of services and resources that the tax professionals at Gudorf Law Group can offer you Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 1

4 Federal Tax Services Constantly up-to-date on the latest IRS rules and regulations, Gudorf Law Group s Federal Tax Team offers a broad range of capabilities in the following areas: Tax Compliance and Consulting Services With our full-service approach, our team of tax attorneys and professionals help businesses make decisions in accordance with the rules and regulations pertaining to federal, state, and local income and franchise taxes, including advisory in the following areas: Tax Compliance Services: We provide federal tax compliance services Our standard compliance methodology can help improve corporate efficiency in the process Our service philosophy is simple: listen, learn, and understand everything there is to know about each one of our clients By looking at the world from the perspective of our clients, our team of talented and proven tax professionals are able to provide practical services and advice that are in sync with your business goals and values Day-to-Day Tax Advisory Services: Our tax professionals offer tax compliance planning and tax provision support as well as analyze the overall tax position of an organization Tax Provision Services: When the need arises, Gudorf Law Group can assist with the preparation of income tax provisions Tax Co-Sourcing Services: Our service includes the use of a clear and structured sourcing approach to help companies determine the best fit for their organizations and determine whether local outsourcing, co-sourcing, or offshore resources provide the best option and provide the necessary services to augment your tax department Tax Transformation Services Gudorf Law Group's Tax Transformation professionals can help your company s tax department operate more efficiently and effectively to bring tangible benefits to the company while also enhancing its reputation within the organization GUDORF LAW GROUP S TAX SERVICES 2 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

5 Tax Controversy and Litigation Services Gudorf Law Group s Tax Controversy and Litigation Services (TCLS) professionals help companies understand, anticipate, and strategically respond to the IRS, from the beginning of a controversy to its final resolution Our TCLS professionals have successfully sustained client tax positions in both the administrative appeals process and in the US Tax Court Although it is our goal to settle all disputes without litigation, we do not hesitate to defend our clients in court Our primary services include: IRS Examination Tax Advisory and Appeals Assistance: We provide traditional tax consultation services in the examination context as well as preparing protests and representing client in the appeals process Alternative Dispute Resolution: Our TCLS professionals can assist clients in determining which alternative dispute resolution technique, such as mediation (Fast-Track Settlement and post-appeals), arbitration, early referral, pre-filing agreements, and accelerated issue resolution, may fit each specific situation Tax Litigation: Only when advantageous to our clients legal and financial interests, we will litigate a client s tax position in court Interest Computation Assistance: We analyze IRS transcripts, review the interest computations, and correctly apply computational procedures to help companies successfully identify errors that could lower interest liabilities or create interest refunds Today s economic challenges are forcing governments around the world to step-up tax enforcement in an effort to sustain revenue At the same time, companies are having to take a more proactive approach to minimizing their tax burdens in an effort to sustain both corporate revenue and shareholder value Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 3

6 State and Local Tax Services Gudorf Law Group s State and Local Tax (SALT) professionals offer a broad range of state and local tax services to our clients We continually monitor the legislative, judicial, and regulatory tax landscape of each and every state in the country to keep our clients abreast of new developments that may affect them Our SALT services are organized into the follow distinct yet still interconnected areas: Income and Franchise Tax Services Through a broad array of tax advisory, controversy, and compliance services, our professionals can help clients manage the complexities of nexus, apportionment, tax base, income classification, and filing options Services include: Income Tax Compliance We continually monitor the legislative, judicial, and regulatory tax landscape of each and every state in the country to keep our clients abreast of new developments that may affect them State Amended Returns Provision Review Apportionment Analysis Controversy Services US Indirect Tax Services Well-versed in multi-state issues that affect both US-headquartered and non-us- headquartered companies, our professionals provide a range of services, including: Sales Tax Compliance Recovery of Overpayments State Audit Defense Transaction Tax Systems Exemption Certificate Compliance Voluntary Disclosure Services Sales and Use Tax Outsourcing GUDORF LAW GROUP S TAX SERVICES 4 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

7 Indirect Tax Services Value-Added Tax (VAT) Services Unclaimed Property Services Employment Tax Services Our professionals can help companies identify payroll and unemployment tax issues by: Identifying, quantifying and recovering payroll tax overpayments Complying with employment tax requirements during restructuring or related M&A transactions Securing the abatement of penalties for payroll-related assessments State Tax Resource Network SALT s STRN brings together professionals from across the United States to provide timely access to tax insights and guidance that can help address tax issues that may affect their competitiveness and ability to meet long-term business objectives As part of our approach, our STRN professionals: Gain an in-depth understanding of a client s business to provide high-quality representation Work collaboratively within the network, leveraging the knowledge and experience of Gudorf Law Group s SALT professionals We are a team of tax professionals that is dedicated to formulating long-term tax strategies that are backed with substantial legal authority Help a client determine which procedural route to pursue: settlement, conciliation, conferences, or administrative hearings Assist the client through the administrative appeals process National Location and Expansion Services (NLES) Gudorf Law Group s NLES offers assistance with expansion-based business services including: Site Selection and Location Analysis, Credit Review, and Economic Development Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 5

8 Tax Exempt Organization Services Gudorf Law Group s Tax Exempt Organizations Team handle the formation and operation of tax-exempt entities of all types We offer the following services: We know the importance of details We listen to our clients We learn everything there is to know about each one of our clients We understand each one of our clients Advise on formation of non-profit corporations and charitable trusts Assist with tax exemption applications and private letter ruling requests to the IRS Advise on domestic and international grant-making issues, charitable solicitation and fundraising compliance Structure mergers, acquisitions and joint ventures of non-profits Advise on the creation of complex structures involving both for-profit and not-for-profit entities Represent clients in state and federal audits and appeals on compensation and excess benefit issues Develop planned giving programs Advise on corporate governance and conflict of interest issues Counsel on director and officer liabilities Fundraising and Donor-Related Services Charitable giving presents ever-changing and often-overlooked issues for the donor and recipient We can advise clients on IRS gift acknowledgment requirements We can assist nonprofit organizations and their development officers on current and deferred charitable giving matters, including gifts of cash, appreciated land or securities, personal residences, and other forms of real and personal property We can also work with clients and prospective donees in planned giving transactions using charitable remainder unitrusts and annuity trusts, charitable lead trusts, pooled income funds and other strategies GUDORF LAW GROUP S TAX SERVICES 6 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

9 Expertise You Can Rely On We are well versed on the tax laws that apply to tax-exempt organizations of all types; national and international charities, family and corporate foundations, universities, private schools and charter schools, student exchange organizations, cultural institutions, social service agencies and research organizations, trade and professional associations, social clubs, religious organizations and advocacy groups We Counsel All Types on Tax Exempt Organizations We can also serve as legal counsel to a broad spectrum of other types of nonprofit organizations, including providers of housing for low-income families or for the disabled, hospitals, medical research organizations and other health care organizations, churches and other religious organizations, universities and other types of educational institutions, community foundations, labor unions, national collegiate fraternities and sororities, social welfare organizations, trade associations and business leagues, and political organizations Private Foundation Advisory Services We have extensive knowledge with regard to the private foundation regulations, including the annual distribution requirement and the rules on domestic and foreign grant-making, and the prohibitions against self-dealing, jeopardizing investments, excess business holdings and taxable expenditures Health Care Organizations We can represent tax-exempt health care organizations and organizations in other specialized industries For example, we can serve as counsel in joint operating arrangements, horizontal integrations, conversions and sales of assets and the resulting foundations, joint ventures, physician practice acquisitions, academic medical center relationships with physicians, and captive insurance and other risk management arrangements By looking at the world from the perspective of our clients, our team of talented and proven tax professionals are able to provide practical services and advice that are in sync with your business goals and values Tax-Exempt Bond Financing We can provide Section 501 (c)(3) tax opinions in tax-exempt bond financings and advise clients on the rules governing low-income housing and student housing We also obtain and maintain real property tax exemptions for our clients Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 7

10 International Corporate Services Gudorf Law Group s International Corporate Services (ICS) professionals are committed to helping companies achieve efficiency in their international operations We have the knowledge, experience, and technical skills to advise clients on every aspect of international taxation from both inbound and outbound transaction perspectives Our understanding of ever-changing cross-border business practices as well as our extensive knowledge of tax laws and general business conditions in jurisdictions around the world allow us to provide specialized services to assist clients with current issues and achieving business objectives ICS professionals provide a broad range of tax consulting services that assist clients with: We understand the concern for compliance, concern regarding corporate reputation, and the complexities of your industry as well as the global market We provide effective international tax planning strategies that involve multiple jurisdictions Establishing new operations, including joint ventures Organizing or modifying distribution networks through foreign affiliates Planning low-cost financing structures and alternatives Reviewing foreign manufacturing and service operations Integrating global operations based on business needs Complying with US tax, tax accounting, and international trade requirements We provide effective international tax planning strategies that involve multiple jurisdictions We collaborate with our foreign network partners to ensure that all tax strategies are effective both in the United States and abroad GUDORF LAW GROUP S TAX SERVICES 8 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

11 Mergers, Acquisitions, and Restructurings Gudorf Law Group s Mergers and Acquisitions (M&A) Team of tax attorneys and professionals have both the global perspective and tax law knowledge needed to facilitate a merger, acquisition, or tax-free corporate reorganization Specific services include: Due Diligence: Careful due diligence helps apprise clients of the potential risks and benefits associated with a particular transaction We base our investigations on an understanding of our clients' strategy and business goals so we can help identify the particular tax exposures that will be addressed Acquisition Tax Planning: Our team can help lay the groundwork for an acquisition, perform tax-efficient planning, and provide traditional tax due diligence on the prospective company, its group members, or other parties involved in a joint venture Disposition Tax Planning: While also encompassing tax due diligence and transaction planning, this set of services focuses on the particular characteristics of a disposition We can help ascertain the potential tax issues that may arise upon the sale or disposition by other means of all of part of a business We can help clients address a variety of issues, including the retention of certain assets, debt placement, and a tax-efficient method for disposition Our M&A Team of tax attorneys and professionals have both the global perspective and the law tax law knowledge needed to facilitate a merger, acquisition, or tax-free corporate reorganization Services Related to Troubled Companies: Our M&A tax professionals can help clients at virtually every phase of a difficulty, including layoffs, division shutdowns, debt negotiations, bankruptcy petitions, and liquidations Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 9

12 Private Wealth Services Our highly experienced wealth planning attorneys have prepared and implemented countless estate plans for high-net-worth individuals, multigenerational families and international clients using a broad range of sophisticated strategies and techniques, from traditional to esoteric Gudorf Law Group s Private Wealth Services Team provides services in the following areas: Our Private Wealth Services Team has prepared and implemented countless estate plans for high-net -worth individuals, multigenerational families and international clients using a broad range of sophisticated strategies and techniques, from traditional to esoteric Estate, Gift and Generation-skipping Transfer Tax Planning Business Succession Planning Lifetime or Multigenerational Gift Programs Asset Protection FATCA Compliance for Offshore Accounts Probate Litigation Life Insurance Planning with Irrevocable Trusts Private Placement Life Insurance Sophisticated Charitable Giving Charitable Organizations Private Foundations Prenuptial and Postnuptial Planning Planning for Entrepreneurs International Planning for International Clientele Private Company Services Gudorf Law Group s Private Company Team represents privately and closely held companies in all aspects of their business operations Our lawyers guide family business owners through the entire life cycle of their company, from entity formation, financing and corporate governance issues to tax planning, transfer of wealth and business succession planning Our priority is to manage your business objectives alongside your personal goals to create a seamless plan that accomplishes both GUDORF LAW GROUP S TAX SERVICES 10 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

13 Dispute Resolution and Litigation Our team is equipped to handle complex probate litigation anywhere in the United States as well as the following: Trusts and will contests Defense and prosecution of fiduciary surcharge proceedings Contested conservatorship and guardianship matters Will and trust construction Interpretation and reformation proceedings Estate and gift tax litigation matters in many different state courts and the US Tax Court Working closely with our Tax Controversies and Litigation Team to achieve optimum results through negotiation, litigation, trial, appeal and alternative dispute resolution methods, we represent individuals, celebrities, family businesses, charitable organizations, educational institutions, banks, and trust companies Estate Tax Preparation and Compliance In addition to the estate administration process, our lawyers counsel clients on tax-related activities for businesses, individuals and estates, including the preparation of estate tax and income returns, planning to minimize transfer taxes, representation in estate tax law controversies and a full range of post-mortem planning (including qualified disclaimers and the use of the credit for tax on prior transfers) Wealth Transfer Services Our Wealth Planning Team assists high-net-worth clients to attain and maintain their financial and wealth planning goals through sophisticated wealth transfer arrangements We work continually with families and their advisors to devise and implement comprehensive plans that match and adjust to each family's distinct attributes We understand that wealth is built, protected and transferred through a team effort Therefore, we encourage each client to assemble a team of professionals who will collaboratively design and implement a plan that balances the current and future needs of the estate Our Wealth Planning Team assists high-net -worth clients to attain and maintain their financial and wealth planning goals through sophisticated wealth transfer arrangements Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA GUDORF LAW GROUP S TAX SERVICES 11

14 Sophisticated Planning Requires Understanding and Attention Our Wealth Planning and Preservation Team understands that the most effective method for successful wealth planning and preservation is investing the time to learn about each client s long-term goals, family situation, business holdings, and insurance policies to see the big picture before recommending a course of action Each wealth plan we devise is unique because each client s current circumstances and long-term goals are different Every comprehensive lifetime wealth transfer plan we develop involves an iterative process that includes continual attention and adaptation to ensure that it remains responsive to changes in your current situation and future goals As your wealth, family circumstances and the laws change, so must the plan Therefore, we work with you over the course of your lifetime, in collaboration with your other professional advisors, to help you reach and maintain your goals and preserve your family heritage Every comprehensive lifetime wealth transfer plan we develop involves an iterative process that includes continual attention and adaptation to ensure that it remains responsive to changes in your current situation and future goals Estate Administration Our team also engages in all aspects of probate and trust administration, both domiciliary and ancillary In addition to the administration process, we assist you with tax-related activities for estates that regularly include the preparation of estate tax and income tax returns, representation in estate tax controversies and a full range of post-mortem planning, including qualified disclaimers and the use of the credit for tax on prior transfers Offshore Tax Compliance Our Offshore Tax Compliance Team counsels individuals on the unique tax consequences associated with their foreign investments If engaged prior to the investment, we can counsel on how to properly structure and report the investment to minimize the associated tax obligations while complying with current tax laws If engaged after the investment, we can restructure and resolve all compliance issues associated with the investment Similarly, we assist corporate fiduciaries with tax compliance issues associated with their foreign beneficiaries GUDORF LAW GROUP S TAX SERVICES 12 Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-Printed in the USA

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16 Contacts John Anthony Castro, JD, LLM Principal Tax Associate P: E: Ted Gudorf, JD, LLM Managing Partner P: E: wwwgudorf Lawcom Copyright 2013 Gudorf Law Group, a US limited liability company All rights reserved Self-designed and printed in the USA