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.
The firm handled the real estate and opportunity zone structuring for a $25 million adaptive re-use project for a developer on the west side of the Atlanta Beltline that also involves state and federal historic tax credits.
The firm structured all aspects of an opportunity zone real estate investment, including forming the Qualified Opportunity Fund, of a $50 million adaptive re-use project in Greenville, South Carolina including a brewery, retail and a multifamily component.
On behalf of the developer, the firm formed a Qualified Opportunity Fund for a $100 million new office development in the Heights Union district of Tampa, Florida.
Lead counsel in various opportunity zone transactions pursuant to 26 U.S.C. Subchapter Z, including significant office development in south Florida, mixed-use retail and multi-family adaptive re-use project in Greenville, SC and office and multi-family adaptive re-use project on west Atlanta’s “Beltline”. Cumulative transaction value in excess of $150 million.
IRS agreed that taxpayers who raised cattle and ducks for their duck hunting preserve were engaged in farming activities for profit.
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.
Represented a bank lender in the financing of a tax credit syndicate using ownership interests in the entities owning film tax credits as collateral for the loan.
IRS agreed owner of Lear Jet entitled to interest, deprecation and operating expense deductions.
Represented one of the world's largest religious organization before the Georgia Department of Revenue, which agreed not to impose sales use and lodging taxes on use of lodging facility by church members and related groups.
Representing business entities in a wide variety of industries on tax 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 Employee Stock Ownership Plan ("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.
Represented 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.
Represented 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.
- Appeals Officer Abused Discretion in Failing to Verify Notice of Deficiency Was Properly Mailed, Bloomberg Law TaxMay 31, 2019
- December 6, 2018
- November 28, 2018
- September 18, 2018
- August 9, 2018
- Fed. Claims Court Won’t Halt Gov’t $59M Credit Win For Appeal, Law360July 3, 2018
- Your options for exemptions in GeorgiaSuper Lawyers Magazine, June 2018
- June 4, 2018
- Daily Report, March 28, 2018
- March 21, 2018
- February 1, 2018
- December 13, 2017
- Cobb Business Journal, November 17, 2017
- November 10, 2017
- November 10, 2017
- November 6, 2017
- October 31, 2017
- October 30, 2017
- 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
- August 15, 2019
- December 6, 2018
- November 1, 2018
- Nine Attorneys Also Recognized as Leaders in Their FieldsMay 3, 2018
- March 14, 2018
- February 22, 2018
- December 14, 2017
- October 30, 2017
- 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
- International Tax Provisions Are Already in Effect. Is Your Company Ready?ACC Docket, June 2018
- March 6, 2018
- 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
- By: Julian FortunaJune 26, 2019
- By: Ashley Swan and Brian GardnerFebruary 19, 2019
- By: Julian FortunaApril 30, 2018
- By: Brian GardnerApril 11, 2018
- By Julian FortunaMarch 2, 2018
- Authored by: Brian GardnerFebruary 26, 2018
- February 15, 2018
- February 6, 2018
- January 24, 2018
- January 23, 2018
- November 27, 2017
- 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
- Taylor English | 1600 Parkwood Circle, Suite 200, Atlanta, GA 30339, June 6, 2019
- Taylor English | 1600 Parkwood Circle, Suite 200, Atlanta, GA 30339, May 9, 2019
- Taylor English | 1600 Parkwood Circle, Suite 200, Atlanta, GA 30339, March 21, 2018
- An Interactive Hospitality and Retail Law SeriesDavio's | 3500 Peachtree Rd NE Atlanta, GA 30326, January 30, 2018
- "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
- SCOTUS Kaestner Ruling on State Trust Income Taxation: Key Considerations for Trusts and Estates Counsel, CLE WebinarOctober 1, 2019
- June 6, 2019
- Webinar, Listed Transactions Reporting: Conservation Easements, Form 8886 and the IRS Audit Initiative, StraffordMay 28, 2019
- The Buckhead Club, May 13, 2019
- Clear Law InstituteMay 8, 2019
- Real Estate and Property Tax TrendsApril 25, 2019
- April 16, 2019
- National Business Institute, March 11, 2019
- January 16, 2019
- December 13, 2018
- Cobb Galleria Centre, November 29 – 30, 2018
- June 21, 2018
- Cobb Galleria Centre, Atlanta, Georgia, June 14 – 15, 2018
- The Georgia Society of CPAsGSCPA Learning Center, December 6, 2017
- October 30, 2017
- 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
- "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
- "International Tax Issues for the General Practitioner," 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
Global Business Law
Areas Of Focus
- Employee Benefits and Executive Compensation
- Employee Stock Ownership Plans (ESOP)
- Opportunity Zone Transactions
- 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