We understand that the tax structure of every business and investment transaction is critical to financial success. We can guide you with strategies that will allow your business and family to reduce taxes and thereby enhance your earnings and overall wealth.
Our tax practice is notable for the scope and diversity of the matters we handle. We regularly provide tax advice related to the formation, financing, operation, restructuring and disposition of a wide variety of business entities. Our attorneys counsel tax-exempt organizations on formation and operational compliance. We also represent individual, business, trust, estate and tax-exempt clients in civil and criminal tax controversies before federal, state, local and foreign tax authorities and administrative tribunals, and before federal and state courts in tax litigation.
Our tax practice focuses on helping businesses, corporate executives and families enhance and preserve wealth though income, estate and gift tax planning, business succession planning, family wealth planning, charitable giving strategies and employee benefit plans, such as employee stock ownership plans. C-level executives and their employers turn to our attorneys for the structuring of compensation agreements that minimize tax obligations.
Our tax practice is managed by talented and creative attorneys with decades of tax planning and controversy experience, including the former general tax counsel for a company with operations in more than 100 countries, an attorney with Big Four and IRS experience, plus multiple attorneys with the highest peer review ratings and leadership positions in the tax sections of both the Atlanta Bar Association and the State Georgia Bar of Georgia. We frequently publish articles in tax journals and speak at tax conferences before other members of tax bar and associations of certified public accountants.
Represented taxpayer in criminal worker classification case in the Northern District of Georgia. The jury acquitted the taxpayer of all tax charges.
Recently tried conservation easement case involving a charitable contribution deduction on the donation of 500 acres along five miles of navigable water near the Atlantic Ocean. Decision pending in the United States Tax Court.
Obtained innocent spouse relief from all tax liabilities for innocent spouse.
Recently tried conservation easement case involving the disallowance of a charitable contribution deduction on the donation of a golf course to a conservation easement. Decision pending in the United States Tax Court.
Representing a bank lender in the financing of a tax credit syndicate using ownership interests in the entities owning the credits as collateral for the loan.
IRS agreed owner of Lear Jet entitled to interest, deprecation and operating expense deductions.
Georgia Department of Revenue agreed to limit sales tax on use of lodging facility by church members and related groups.
Representing business entities in a wide variety of industries on top matters related to formation, financing, operations, restructuring, and dispositions.
Represented business owners, plan sponsors, trustees, lenders, and related clients in a wide variety of tax issues arising in ESOP transactions ranging in value from $10-$300 million.
Advised numerous S Corporations, LLCs and partnerships, and their owners, regarding initial qualification and the taxation of operating and investment income, raising debt and equity capital, executive compensation, and disposition of assets or entities.
Representing large, complex group of foreign entities, including a private foundation and its founders in an IRS examination involving classification and taxation of entities with more than $50 million of tax and penalties at stake.
Represented retired NFL football player in case where the IRS denied a theft loss the taxpayer suffered when his licensed investment adviser misappropriated $1,679,500 of his funds. Decision pending in the United States Tax Court.
The IRS denied fuel excise tax credits for industrial vacuum loaders known as “Guzzlers” used by an industrial waste removal company.
The government recognized the hazards of litigating the case and agreed for purposes of this case that the equipment qualified as Off-Highway Vehicles engaged in an off-highway business use and, therefore, qualified for the fuel excise tax credit.
The Tax Court agreed that gifts of family limited partnership interests in a family limited partnership for an incompetent taxpayer under guardianship did not violate §2036.
IRS conceded challenge to Amendment Clause in Conservation Easement and settled on eve of trial reducing the alleged deficiency by more than $1.2 million.
The IRS asserted that the taxpayer did not materially participate in his yacht charter business and therefore the business was passive and his losses were not deductible.
Through a chronology of Petitioner’s business records, charter agreements, phone records, emails, and co-worker’s testimonials, the taxpayer established that he not only materially participated in the business operations of his yacht charter business, but also micro-managed that ...
Successfully represented many clients seeking reduced penalties under the IRS offshore voluntary disclosure.
The IRS abated penalties against NFL Football players who unwittingly invested in tax scam and provided information that resulted in criminal indictment of promoter.
Representing solar, wind, and biomass renewable energy developers in the structuring of entities to raise equity and debt supported by tax credits and grants.
Representing large non-profit university with respect to domestic and international tax planning, compliance and controversy matters.
Representing group of investment entities on the tax-deferred sale of large tracts of real estate valued at more than $500 million. Structured all kinds of tax-free like-kind exchanges of real estate, including forward, reverse, construction and related-party exchanges.
Represented clients in investigations or in obtaining an opinion or ruling from state or local taxing authorities regarding the application of sales and use tax to various products and services.
- September 22, 2017
- April 3, 2017
- April 3, 2017
- December 6, 2016
- December 1, 2016
- November 21, 2016
- November 17, 2016
- November 15, 2016
- November 15, 2016
- October 19, 2016
- October 19, 2016
- September 23, 2016
- August 10, 2016
- August 8, 2016
- July 20, 2016
- May 6, 2016
- "Taylor English's Vivian Hoard Invited to Join the Fellows of the American Bar Foundation," Atlanta PatchApril 21, 2016
- "Taylor English's Vivian Hoard Invited to Join the Fellows of the American Bar Foundation," Atlanta CitybizlistApril 21, 2016
- April 18, 2016
- April 15, 2016
- January 6, 2016
- "Local Attorney Named Among Atlanta’s Five Star Financial Service Professionals," Marietta Daily JournalNovember 2, 2015
- April 10, 2015
- January 14, 2014
- June 3, 2013
- December 15, 2016
- December 13, 2016
- November 1, 2016
- August 15, 2016
- April 14, 2016
- December 1, 2015
- November 2, 2015
- August 17, 2015
- Taylor English Tax Attorney, Vivian Hoard, Named One Of Atlanta’s Top Wealth Managers By Five Star Wealth Manager and Atlanta MagazineNovember 3, 2011
- July 31, 2017
- "Transfer Pricing Adjustment Challenges Receive Green Light from the Tax Court,” Journal of TaxationNovember 11, 2016
- Author, The Business Owners' Guide to Handling Tax Issues and the IRS: Tips for Avoiding Trouble with the IRSOctober 2016
- October 7, 2016
- September 30, 2016
- July 6, 2016
- Co-Author. "While You Were Away: Tax Updates from the 2016 Filing Season," Current Accounts, The Georgia Society of CPAsMay/June 2016
- January 3, 2011
- October 6, 2017
- August 22, 2017
- March 7, 2017
- November 8, 2016
- October 13, 2016
- September 26, 2016
- September 22, 2016
- Valuation Discounts for Intra-Family Transfers of Family-Held Business Interests are Proposed to be Curtailed – Act Now!September 12, 2016
- August 12, 2016
- May 24, 2016
- May 16, 2016
- January 14, 2016
- December 8, 2015
- October 21, 2015
- September 30, 2015
- September 23, 2015
- August 19, 2015
- August 11, 2015
- March 6, 2015
- June 3, 2014
- May 31, 2014
- "Captive Insurance Companies: Many Benefits for Middle Market Business Owners and Their Trusted Advisors," Tax TalksDavio's, November 9, 2016
- Cobb Chamber of Commerce, May 10, 2016
- March 27, 2014
- February 26, 2014
- January 15, 2014
- September 25, 2013
- The Ritz-Carlton Reynolds, Lake Oconee, Greensboro, Georgia, July 21, 2017
- "IRS controversy in the Estate, Gift and High Net Worth Individual Area," Estate Planning ConferenceJuly 20–22, 2017
- Kiawah Island, S.C., May 26-28, 2017
- "Updates from the 2017 Filing Season: Developments in Tax Law and Tax Controversy," Georgia Society of CPA's DeKalb Chapter MeetingAtlanta, Ga., May 23, 2017
- "Updates from the 2017 Filing Season: Developments in Tax Law and Tax Controversy," Georgia Society of CPA's Gwinnett Chapter MeetingDuluth, Ga., May 16, 2017
- Atlanta, Ga., March 23, 2017
- "International Tax Issues for the General Practitioner," Institute of Continuing Legal Education: State Bar SeriesAtlanta, Ga., December 15, 2016
- "How to Counsel Clients with Undisclosed Interests in Foreign Entities, Assets or Financial Accounts," Institute of Continuing Legal Education: State Bar SeriesAtlanta, Ga., December 15, 2016
- "Settlement Agreements in Employment Cases—Avoiding the Landmines," Atlanta Bar Association Litigation, Labor & Employment, and Tax Law SectionsAtlanta, Ga., December 9, 2016
- "Options for Handling an IRS Audit When Negotiations Fizzle Out with the Examination Division," Georgia Society of CPAs, 2016 IRS Solutions ConferenceAtlanta, Ga., December 7, 2016
- October 13, 2016
- "What is a §501(c)(3) Tax Exempt Organization and Its Limitations," 2016 Atlanta Bar Association March Madness Pro Bono EventAtlanta, Ga., March 22, 2016
- "Handling an Eggshell Audit" and "Criminal Tax Defense," AAA-CPA 2015 Fall Meeting & Education ConferenceCharleston, S.C., November 12, 2015
- "The Criminal Tax Coffee Klatch," The Georgia Society of CPAs 2015 Georgia Tax Forum, November 5 and December 3, 2015Atlanta, Ga.
- "The IRS Office of Appeals: They Can Work for You," Southeastern Accounting Show, The Georgia Society of CPAsAtlanta, Ga., August 27, 2015
- Atlanta Business Radio, June 19, 2015
- December 18, 2014
- December 17, 2014
- "2013 Income, Estate and Gift Tax Update," The Seminar GroupFebruary 27, 2014
- "IRS Tax Resolution Matters," Federal Tax Day 2014, AWSCPA-Georgia Chapter
- Qualified Small Business Stock Jonathan B. Wilson
- Taylor English Victory in Litigation Against IRS Jonathan B. Wilson
- Savannah Film Incentive Makes State Even More Competitive Mitzi L. Hill
Emerging Markets Law
Areas Of Focus
- Employee Benefits and Executive Compensation
- Employee Stock Ownership Plans (ESOP)
- Succession Planning for Closely-Held Businesses
- Tax Controversy and Litigation
- Tax Credits and Special Incentives
- Tax Planning for Business Transactions
- Tax-Exempt Organizations and Charitable Giving
- Trust, Estate, and Family Wealth Planning