Tax Law
Tax Law Expertise at Kramer Rayson LLP
Our Tax Law Expertise
We offer a broad range of services to individual taxpayers, businesses, and professionals, including certified public accountants (CPAs) and tax return preparers. Our attorneys have extensive experience navigating the complexities of tax law, and we provide sound legal counsel on a variety of matters, including:
Tennessee Sales and Use Taxes
Tennessee's sales and use tax laws can be particularly complex, and businesses often face challenges with compliance, audits, and disputes with tax authorities. Our attorneys are well-versed in sales and use tax matters and offer tailored guidance to ensure that our clients meet their obligations while protecting their financial interests.
IRS Representation
Dealing with the Internal Revenue Service (IRS) can be daunting. Our firm has a proven track record of successfully representing clients in IRS audits, appeals, and tax disputes. We work diligently to protect our clients' rights and resolve issues efficiently, whether it's negotiating settlements or seeking favorable rulings.
Real Estate Tax Disputes
Real estate tax disputes can have far-reaching financial implications for property owners. Whether contesting property tax assessments or seeking exemptions, our team has the expertise to manage these complex cases and secure the best possible outcome for our clients.
Business and Personal Estate Planning
Tax considerations play a critical role in both business and personal estate planning. We help clients structure tax-efficient plans that minimize liabilities and preserve wealth. Whether you are preparing for the future of your business or planning for heirs, our team provides strategic advice on optimizing your tax situation.
Choosing the Right Business Entity
The choice of business entity can have significant tax implications. We assist clients in evaluating the tax effects of different business structures—such as LLCs, corporations, and partnerships—to ensure compliance with tax laws and maximize tax efficiency.
State and Federal Tax Authority Representation
Our attorneys are highly experienced in representing clients in disputes with both state and federal tax authorities. Whether handling audits, negotiating settlements, or representing clients in litigation, we provide vigorous representation aimed at resolving tax issues efficiently and favorably.
Deferred Compensation and Tax Liabilities
Structuring deferred compensation plans requires a nuanced understanding of tax laws. We guide clients through the complexities of deferred compensation and help address associated tax liabilities to ensure compliance with relevant regulations.
Delinquent and Amended Tax Returns
If you have delinquent or amended tax returns, our attorneys can assist with addressing outstanding tax liabilities, filing amended returns, and negotiating resolutions with tax authorities. We work to minimize penalties and reduce potential exposure to tax enforcement actions.
Offshore Voluntary Disclosure
For clients with offshore assets, we offer expert counsel on offshore voluntary disclosure programs. We help clients navigate the process of disclosing assets to the IRS, addressing associated tax liabilities, and minimizing potential penalties for non-compliance.
Contesting Fraud and Return Preparer Penalties
Fraud penalties or return preparer penalties can have serious consequences. Our firm offers strategic representation to contest these penalties, protecting clients from unjustified claims and helping resolve disputes favorably.
Circular 230 Compliance
Circular 230 imposes strict requirements on tax practitioners. Our attorneys provide guidance to ensure compliance with these regulations and uphold the highest ethical standards in tax practice, helping our clients avoid potential issues with the IRS or state authorities.
A Legacy of Landmark Decisions
Kramer Rayson LLP has a strong history of handling complex tax matters, including many cases with multimillion-dollar implications. Our firm’s reputation is built on landmark decisions and administrative rulings that have shaped the tax landscape for businesses in Tennessee. Notable cases include:
• United States vs. Boyd, 378 US 39, 12 L.Ed.2d 713 (1964)
• Union Carbide Corporation vs. Alexander, 679 S.W.2d 938 (Tenn. 1984)
• Lockheed Martin Energy Systems, Inc. vs. Johnson, 78 S.W.3d 918 (Tenn. App. 2002)
• Aluminum Company of America, Inc. (AJ, Blount Co. Tax Year 1991)
• Clean Harbors, Inc. (AJ, Hamilton County Tax Years 2004-2006)
• Alcoa Inc. (AAC Blount County, Tax Years 2001-2003)
• Saturn Corporation (AJ, Maury County, Tax Years 1996-1999)
These landmark cases reflect our firm’s significant role in challenging attempts by state and local governments to tax large federal contractors, manufacturers, and other businesses. Our firm’s ability to handle high-stakes tax cases, such as advising General Motors in a $7 million tax dispute, demonstrates our expertise in managing complex tax matters with far-reaching implications.
Contact Us Today
With decades of experience in tax law, Kramer Rayson LLP is prepared to handle your tax-related concerns, from state and local tax matters to federal tax disputes. Our attorneys work diligently to protect your interests and ensure compliance with applicable tax laws.
