Tax

The Bradley Arant Boult Cummings Tax Practice Group offers a broad range of services that covers all aspects of federal, state and local taxation. We provide experienced guidance for clients to help them better understand and efficiently manage their business and personal tax obligations.

More than one third of the partners within the Tax Practice Group are elected as Fellows in the American College of Tax Counsel, an elite group of only 700 tax attorneys nation-wide. These professionals are recognized for their excellence in tax practice and for their substantial contributions to the profession.

Our tax attorneys develop solutions that not only address our clients’ legal issues, but also fit their overall financial and business strategies.  We serve a diverse client base that includes regional, national and international publicly-held companies, privately-held businesses, nonprofit and exempt organizations, corporate and individual fiduciaries, and individuals. From our broad geographic base in the Southeast, we are able to meet the needs of regional, national and international clients, regardless of their size or locations. Our attorneys have direct experience handling the unique tax issues presented by a wide range of industries, including health care, banking and financial services, information technology, biotech, and real estate. The firm also represents a substantial number of nonprofit tax-exempt organizations, including charities, religious organizations and nonprofit health care providers.

Our services encompass the full range of federal, state and local taxation issues, including planning and resolution of federal and state tax controversies. We develop and implement plans for both individuals and businesses. Our attorneys have extensive experience advising companies in connection with business transactions, entity formation and capitalization, partnership tax allocations, and real estate acquisitions and disposition. As well, we have assisted clients with reorganizations and the tax issues arising in connection with insolvency and bankruptcy. We also counsel businesses on issues related to executive compensation, including incentive compensation plans. The Tax Practice group includes several experienced trust and estate attorneys who represent business owners, corporate executives, professionals, retirees and other individuals in all aspects of federal and state estate and gift tax planning.

Formation of Business Entities
We advise clients about the tax considerations and alternatives relating to the organization, capitalization, operation, conversion and termination of all forms of business entities including corporations, partnerships, limited liability companies and trusts. We also assist with related organizational issues including partnership agreements, limited liability company operating agreements and shareholder agreements.

Mergers, Acquisitions, Dispositions and Reorganizations
Our tax attorneys work closely with our corporate and securities attorneys to design and implement tax efficient transaction structures consistent with our client’s business objectives with respect to mergers, acquisitions and reorganizations of businesses, from small privately-held businesses to national and international publicly-held companies. We also counsel our clients with respect to tax issues arising in connection with insolvency and bankruptcy.

Partnership and Real Estate Taxation
Our tax attorneys assist clients in structuring the acquisition, ownership and disposition of real property to achieve the most tax efficient structure consistent with the client’s business objectives. Partnerships and limited liability companies frequently are used as vehicles for owning, managing and disposing of real estate. Our tax attorneys have extensive experience in drafting partnership agreements and limited liability company operating agreements, including designing the allocation of profits, losses and distributions for partnerships and limited liability companies that own real estate and other businesses. We also have extensive experience in advising foreign investors with respect to investments in real property located in the United States.

State and Local Taxation
We advise clients with respect to the state tax considerations involved in structuring the ownership and operation of their businesses, as well as resolving disputes with state and local governments.

Estate and Gift Taxation
Our estates and trusts attorneys provide sound and creative advice to individuals and families in structuring estate plans that meet both their tax and non-tax goals. We represent a wide range of clients, including business executives, owners of closely-held businesses, professionals, highly-compensated employees and many other individuals and families. Our estate and trust attorneys assist clients in meeting their goals for transferring assets to family members, preserving wealth and minimizing taxation.

Tax-Exempt Organizations
We advise public and private nonprofit organizations, including private foundations, public charities, religious and educational organizations and nonprofit health care providers with respect to the organizational and operational tax issues. We also advise tax-exempt organizations with respect to the particular issues applicable to mergers, acquisitions and dispositions involving tax-exempt organizations as well as joint ventures between nonprofit tax-exempt organizations and for-profit organizations.

Controversy Resolution
Our tax attorneys are experienced in assisting clients in resolving disputes with state and local governments as well as with the Internal Revenue Service. Our attorneys have significant experience representing clients at all administrative levels, from audit through administrative appeals. In partnership with members of our Litigation Practice, we represent clients in state trial and appellate courts, as well as in the United States Tax Court, the Federal District Court and Federal Appellate Courts.