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 and pass-through entities to nonprofits and multinational corporations.
Depth of Experience
Saul Ewing's Tax Practice consists of attorneys with a range of backgrounds. For example, our attorneys’ credentials include:
- A former President of the American College of Tax Counsel
- The former Chair of the Federal Taxation Committee of the Chicago Bar Association
- A former Vice Chair of the American Bar Association Section of Taxation
- A former Dean of the National Tax Practice Institute
- Two former Chairs of the Tax Section of the Philadelphia Bar Association
- A former chair of the American Bar Association Section of Taxation’s Committee on US Activities of Foreigners and Tax Treaties (USAFTT)
- A former officer of the Taxes Committee of the International Bar Association
- 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
- The author of three Thomson Reuters treatises on taxpayer representation
- A former member of the IRS Advisory Council which advises IRS management
- Former IRS Counsel attorneys
Our attorneys have leadership roles in the American Bar Association and the International Bar Association and are involved in reviewing and commenting on U.S. tax legislation and regulations. In addition, the Tax Practice augments our Corporate, Labor & Employment, Public Finance and Trusts & Estates practice groups.
For Businesses: 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 taxable and tax-free mergers and acquisitions
- Private equity and venture capital funding transactions
- Real estate acquisitions, dispositions, and investments, including like-kind exchanges, UPREITs, REMICs and REITs
- Inbound and outbound international transactions
- Public financing
- Insurance demutualization and compliance
- State and federal tax audits
- IRS collection representation
- Offers in compromise
- Tax litigation
- Representation before the Criminal Investigation Division of the IRS
- 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 attorneys have 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
We assist our multinational clients in developing efficient cross-border transactional and operational structures and configuring their businesses to minimize U.S. income and withholding taxes, particularly in connection with the acquisition of U.S. businesses and integration of those businesses into their global structure.
For a selection of our tax representations, click here.
- Non-U.S. based distributors of mobile applications on structuring sales into the United States.
- A non-U.S. financial institution on establishing offices within the U.S. and offering products to multi-jurisdictional investors.
- A U.S.-based real estate group on structuring its investment in new major shopping centers in Poland.
- A U.S.-based energy company on restructuring its non-U.S. investments and preparing for future acquisitions.
- A multinational cloud service provider on restructuring matters.
- Multiple non-U.S. based real estate groups on structuring U.S. real estate investments.
- A Canadian company regarding U.S. tax treaty matters.
- A U.S.-based pharmaceutical company on the acquisition of patent rights and post-acquisition manufacturing and sales matters.
- Ireland-based fund managers on structuring investments with U.S. participants and counterparties.
- A financial services group on structuring operations in Latin America.
- A closely held business with operations and owners located in and outside the U.S. on structuring and succession planning issues.
- A mix of U.S. and foreign investors in structuring joint ventures and investment funds to facilitate cross-border investments.
- ConAgra, Deluxe Corporation, Comfort Systems and Staples, Inc., among other corporations, in Maryland income tax cases, and Travelocity in a Maryland sales tax case.
- EarthData companies in successfully representing them in three Maryland sales tax cases.
- A client in successfully litigating a case before the United States Supreme Court, which found that the IRS was barred by statute of limitations from asserting a $10 million deficiency.
- A client in the successful outcome of suing the IRS three times for contempt of court for violation of bankruptcy court stays in which we were awarded attorneys’ fees to be paid by the IRS in each case.
- A former heavyweight boxing champion in successfully negotiating a settlement of a $22 million deficiency against him.
- A Fortune 500 company executive in successfully negotiating an offer in compromise, reducing his tax liability from $50 to $5 million.
- Multiple clients in the management of voluntary disclosure agreements and similar IRS disclosures.
- The borrower in connection with a multi-state tax-exempt/taxable financing transaction through multiple financing authorities.