Recognized by U.S. News & World Report
and Best Lawyers®

National Tier 2, Tax Law

National Tier 3, Litigation - Tax

Metropolitan Tier 1, Dallas/Fort Worth & Houston
Tax Law

Metropolitan Tier 1, Dallas/Fort Worth
Litigation - Tax

Corporations and individuals both foreign and domestic­ rely on our tax lawyers to help with complex state, federal and international tax issues and disputes in a practical, cost-effective way. We have deep, across-the-board experience on which clients rely to design and implement transactions and business structures to minimize taxes – especially in the middle market real estate and energy industries.

We understand tax planning for all phases in the life cycle of a business, from startup through capitalization, operations, growth and disposition or exit strategy. Our clients include:

  • C and S corporations
  • Multinational corporations
  • Consolidated groups
  • Partnerships
  • Limited liability companies
  • Professional associations
  • Tax-exempt organizations
  • Sole proprietorships and individuals
  • Disregarded entities

In addition to our corporate tax planning and counsel, we are highly regarded for our representation of clients in tax controversies, administrative hearings and in the courts. We also have a strong presence in lobbying and government relations.

Tax Practice Essentials

We have represented clients in tax matters relating to foundation self-dealing and unrelated business taxable income, bankruptcy, charitable organizations, qualified settlement funds, low-income housing tax credits and taxation of intellectual property. In addition, our corporate tax attorneys have extensive experience in:

  • Mergers and acquisitions in all industries
  • Leveraged leases and sale-leasebacks
  • Corporate, partnership, and joint venture planning, including choice of entity and check-the-box issues
  • Real estate development activities, and insolvency and workout arrangements
  • Section 1031 like-kind exchanges and tenancies-in-common (TICS)
  • Capital gains and loss planning
  • Closely-held business succession planning and family limited partnerships
  • Allocation of purchase price
  • Debt-equity issues
  • Financial instruments
  • Reasonable compensation
  • Accounting method issues, including inventory methods and capitalization issues
  • Research and development credits
  • Consolidated returns and tax-sharing agreements
  • Depreciation and amortization methods
  • FIN 48 issues
  • Bad debt write-offs, worthless stock and cancellation of indebtedness income
  • Qualified settlement funds
  • Economic development grant and regional tax incentives
  • Employment taxes and responsible person penalties
  • Tax indemnity agreements
  • Reasonable cause penalty waivers
  • Tax shelter issues
  • Off-balance sheet financing

Tax Controversies

Gardere's tax controversy attorneys are recognized consistently as one of the best controversy practices in the state of Texas. This comes from years of experience in the courtroom,­ including U.S. Tax Court and U.S. district courts ­and in administrative negotiations with the Internal Revenue Service.

International Tax and Transfer Pricing Practice

Our international tax lawyers are experienced with international tax planning, transfer pricing and controversies, representing U.S. and foreign-owned multinationals in a variety of matters.

Voluntary Disclosures

We have assisted numerous taxpayers in making Offshore Voluntary Disclosure Initiative disclosures. Taxpayers who have unreported foreign assets or income may voluntarily disclose those assets or income to the IRS pursuant to the ongoing OVDI.

Tax Policy

Gardere's state and federal tax attorneys have developed strong working relationships with tax officials at the highest levels in Texas and the U.S. federal government. We actively monitor tax legislative and regulatory developments that may impact the interests of our clients and their industries. We regularly participate in the taxpayer comment process for tax regulations, obtain private letter rulings for clients and work with the negotiators of international tax treaties.

State and Local Tax Matters

Our tax practice provides experienced state tax planning advice and representation in controversies regarding all aspects of state revenue and income tax (particularly the Texas “margin” tax), sales and use tax, ad valorem tax and other state and local taxes as they apply to both in-state and out-of-state businesses.

Accounting for Tax Matters/FIN 48

Our corporate tax attorneys are at the forefront of matters involving enactment of the Sarbanes–Oxley Act and efforts of the Financial Accounting Standards Board (FASB) to prevent the inappropriate manipulation of tax matters to achieve desired financial accounting results (FIN 48). We routinely evaluate tax positions that have given rise to client-auditor disagreements. In some cases, we are asked to seek advance or pre-filing agreements or letter rulings with respect to the issue.

Energy Tax Issues

Although we have assisted and represented taxpayers in almost every industry, as a Texas-based law firm, many of our clients, particularly those of our Houston office, are in the energy industry. As a result, we have developed a significant depth of experience in the application of specialized rules applicable in all energy industry contexts.

Our tax lawyers are experienced in the tax treatment and issues associated with choice of entity, including corporations, limited liability companies, partnerships and master limited partnerships for energy related businesses, and in guiding clients through their structuring choices.

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