Tax Law
Addressing A Wide Array Of Tax-Related Matters
Our tax law practice is dedicated to providing comprehensive legal guidance and representation to individual taxpayers, businesses, return preparers, and certified public accountants (CPAs). With extensive experience in a wide range of tax matters, our skilled attorneys are well-equipped to address the complexities of today's tax landscape.
Our Expertise
Tennessee Sales and Use Taxes
Navigating Tennessee sales and use tax laws can be complex, but our team is here to help. Whether you're facing compliance issues, audits, or disputes with tax authorities, we provide strategic guidance and representation tailored to your specific needs.
Representation before the IRS
Dealing with the IRS can be intimidating, but you don't have to face it alone. Our attorneys have a proven track record of success in representing clients before the Internal Revenue Service. From audits to appeals, we are dedicated to protecting your rights and interests every step of the way.
Real Estate Tax Disputes
Real estate tax disputes can have significant financial implications, but our team has the experience and expertise to help you navigate these challenges. Whether you're contesting property tax assessments or seeking exemptions, we work tirelessly to achieve the best possible outcome for our clients.
Business and Personal Estate Planning
Taxation concerns are a critical component of business and personal estate planning. Our attorneys provide strategic guidance and assistance with tax planning strategies designed to minimize tax liabilities and maximize wealth preservation for our clients and their heirs.
Choice of Business Entity
Choosing the right business entity can have significant tax implications. Our team assists clients with evaluating the tax implications of different business structures, including LLCs, corporations, and partnerships, to ensure optimal tax efficiency and compliance with applicable tax laws.
Representation before State and Federal Tax Authorities
Whether you're facing an audit or dispute with state or federal tax authorities, our attorneys are prepared to provide vigorous representation on your behalf. We have a proven track record of success in resolving tax disputes through negotiation, mediation, and litigation.
Deferred Compensation and Tax Liability
Navigating deferred compensation and tax liability issues requires careful planning and strategic guidance. Our attorneys assist clients with structuring deferred compensation plans and addressing associated tax liabilities to ensure compliance with applicable tax laws.
Delinquent and Amended Tax Returns
If you have delinquent or amended tax returns, our team can help. We work with clients to address outstanding tax issues, file amended returns, and negotiate favorable resolutions with tax authorities.
Offshore Voluntary Disclosure
Navigating offshore voluntary disclosure programs requires specialized knowledge and expertise. Our attorneys have experience assisting clients with disclosing offshore assets and addressing associated tax liabilities while minimizing potential penalties.
Contesting Fraud Penalties and Return Preparer Penalties
Facing fraud penalties or return preparer penalties can have serious consequences, but our attorneys are here to help. We provide strategic representation to contest penalties and protect our clients' rights and interests.
Circular 230 Requirements
Circular 230 imposes strict requirements on tax practitioners, but our attorneys have a thorough understanding of these regulations. We provide guidance and assistance to ensure compliance with Circular 230 requirements and maintain ethical standards in tax practice.
A Legacy Of Landmark Decisions
Kramer Rayson LLP has handled many cases with multimillion-dollar tax implications. Recently, we advised General Motors in a matter pertaining to $7 million in taxes, demonstrating our firm's ability to handle complex and high-stakes tax matters.
The long history of our firm’s work in this area can be seen in landmark cases and administrative decisions such as:
- 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, 2005 and 2006)
- Alcoa Inc. (AAC Blount County, Tax Years 2001, 2002 and 2003)
- Saturn Corporation (AJ, Maury County, Tax years 1996 – 1999)
These cases reflect important challenges to attempts by state and local governments to tax major federal government contractors as well as large-and medium-sized manufacturers and other businesses in Tennessee.
