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Navigating the Complex World of Tax Law

Saul Ewing's Tax practice offers focused, in-depth knowledge of the intricacies associated with federal, state, and local tax law. The role of the Tax practice is to provide clients with advice and representation in a wide variety of tax-related legal issues. In that role, we provide counsel on minimizing tax impact, both in the current financial situation and for future tax savings, on a small or large scale, domestically and internationally. We represent clients ranging from individuals to pass through entities to nonprofits to multinational corporations.

Depth of Experience

Saul Ewing's Tax practice consists of attorneys with a range of backgrounds. For example, among our attorneys are:

• A former Chair of the Tax Section of the Philadelphia Bar Association
• Current Vice Chair of the Tax Section of the Philadelphia Bar Association
• A member of the American Bar Association's Tax Section and Foreign Activities of U.S. Taxpayers (FAUST)
• A member of the State Tax Committee of the Maryland Chamber of Commerce
• A former assistant Branch Chief of the Office of Chief Counsel, Legislation and Regulations Division of the Internal Revenue Service
• A former special appointee to the U.S. Department of Justice

Our attorneys are active in the American Bar Association and are involved in reviewing and commenting on U.S. tax legislation. In addition, the Tax practice augments the Business and Finance Department and the Labor, Employment and Employee Benefits, Public Finance and Personal Wealth, Estates, and Trusts  practice groups.

For Corporations: Tax and Profitability

Tax issues have major profitability implications for all types of businesses at every stage of their development – including start-ups, small closely held family businesses, nonprofits, and large publicly traded corporations, domestic or foreign. Saul Ewing's Tax attorneys advise clients on a broad range of tax issues, including:

• Strategic tax planning and documentation for mergers and acquisitions
• Inbound and outbound international transactions
• Public financing
• Insurance demutualization and compliance
• State and federal tax audits
• Tax litigation
• State income, sales and use and property tax issues
• Litigation settlements
• Other specialized areas

State taxation of out-of-state corporations is an area of particular concern for some corporations. In a test case with national implications, Saul Ewing represented a Delaware trademark protection company with no physical presence in Maryland in a dispute regarding Maryland state income taxes.

For Multinational Corporations: Making Sense of Complex Tax Issues

Saul Ewing's Tax practice has more than 20 years of experience representing multinational corporations in issues including:

• U.S. taxation of income earned outside the country
• Application of foreign tax credit
• Taxation of foreign persons and businesses earning income in the United States

For example, we have assisted our multinational clients in structuring their businesses to minimize U.S. withholding taxes.

For Nonprofits: Special Concerns

Saul Ewing's Tax practice advises major medical systems, universities, community organizations, quasi-governmental entities, and private foundations with regard to tax law. Nonprofits have a distinct set of needs and concerns, including:

• Advice on formation and organizational structure
• Representation in tax exemption status proceedings before federal and state tax authorities
• Counsel on particular tax issues, such as the new Pennsylvania tax statute defining institutions of purely public charity

Individual, Estate and Gift Taxes: Strategies for Reduction

Saul Ewing's Tax Practice Group also represents individuals who encounter issues with regard to income, estate, and gift taxes. To help minimize the tax "bite," we:

• Advise clients on strategies for reducing federal, state, and local taxes
• Suggest strategies to take advantage of tax incentives
• Work with estates and trusts to develop estate planning strategies such as family limited partnerships, irrevocable insurance trusts, maximizing use of the annual gift tax exclusion, charitable remainder trusts and grantor-retained annuity trusts