Tax Services

Corporate Taxation

» Acquisition and reorganization consulting for buyer or seller
» Structural review for planning opportunities
» Distributions planning
» Liquidation
» Consolidated return issues
» Alternative minimum tax
» Accounting periods and methods
» Cost recovery
» Assistance with IRS examinations
» Tax return preparation

Partnership Taxation

» Review of partnership agreements
» Structuring allocations
» Basis and liability issues
» Return preparation

International Operations

» Structuring international operations
» International reorganizations
» Planning to avoid Subpart F provisions
» Foreign tax credit planning
» Foreign Sales Corporations

State Tax Planning

» Minimizing Texas Franchise Tax
» Multi-State planning techniques
» Nexus issues
» Return preparation

Individual Tax Services

» Deferred compensation arrangements
» Assistance with IRS examinations
» Return preparation

Tax Malpractice Claims

» Experts for either plaintiff or defense

Structured Settlement Consultants

» Technical advice for tax avoidance
» Working relationship with technical experts at IRS National Office

Liquidating Trust and Settlement Fund Creation

» Planning
» Tax return preparation

Analysis of Tax Returns to Identify Issues Relevant to Litigation

» Identification of assets to assist with pre- and post-judgment discovery
» Comparative Net Worth Analysis to evaluate accuracy of tax returns
» Obtaining IRS transcripts to discover taxpayer history

Insolvency Taxation

» Disputing IRS Claims in Bankruptcy
» Carrying Back Losses to Create Refunds
» Reporting to the IRS by Various Types of Entity in Bankruptcy
» Tax Planning for Insolvent Individuals
» Preparation of Memorandum Regarding Potential Tax Issues

Examples

» Assisted client in structuring sale of partnership interest which resulted in federal income tax savings of over $135,000 and state tax savings of $88,000.
» Represented a client in dispute with Internal Revenue Service which resulted in the settlement of an original estimated liability of $2,400,000 for approximately $500,000.
» Assisted client in identifying favorable withholding tax provisions which resulted in over $40,000 in annual withholding tax savings.
» Performed Texas Franchise tax reviews of previously filed state income tax returns and identified refund opportunities in excess of $60,000.
» Assisted client in structuring family limited partnership and implementing gifting strategy which resulted in substantial reduction in projected estate tax liability.
» Performed analysis of separate and community tax calculations in estate dispute which resulted in reimbursement to community estate of approximately $250,000.
» Developed alternative operating structure for corporation which resulted in annual state tax savings of more than $150,000.
» Structured settlements of personal injury claims to minimize allocation of awards to punitive damages which resulted in tax savings of over $250,000.
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