Tax Planning

Tax Planning

Dow Lohnes Price is uniquely positioned to provide a wide range of strategic tax planning and research services. Its extensive Dispute Resolution practice provides a depth of experience which allows the firm to provide strategic and insightful Tax Planning services on “hot topic” issues. The firm is also able to offer maximum privilege through its relationship with Dow Lohnes.

The firm does not market Tax Planning ideas and we will never attempt to “sell” an idea to a client; if we see an opportunity applicable to your company, we’ll simply share it with you.

Our clients receive the full benefit of our experience and knowledge regardless of whether they are asking for our first impression or the benefit of a full research service with regard to the issue. The firm’s Tax Planning services include:

  • Review corporate entity structure and proposed restructuring. 
  • Evaluate the client’s existing or proposed intangible holding company. 
  • Review a client’s previously established tax return filing positions, identifying exposures and making recommendations. 
  • Provide advice regarding practical considerations, documentation and substantiation to establish intercompany notes to support the deductibility of intercompany interest expense. 
  • Review and evaluate recommendations arising from tax planning and research services provided by the client’s auditors or other advisors. 
  • Determine options regarding non-corporate entity structures including limited liability companies, single member limited liability companies and partnerships based on specific state law and business opportunities.
  • Provide advice regarding state tax treatment of income and expenses from flow-thru entities and factor representation of such entities.  
  • Identify and advise regarding elections, credits and planning opportunities based on the nature of the client’s business. 
  • Provide advice regarding location of business activities for state and local tax minimization.
  • Determine whether nexus exists and identify nexus-related tax planning opportunities. 
  • Provide advice regarding practical considerations, documentation and substantiation of intercompany management fee allocations to support the deductibility of intercompany fees and expenses.
  • Identify possible filing options for each state and prepare/review computations to determine the cost versus the benefit of various filing options.  
  • Evaluate settlement offers arranged by other firms in their handling of a dispute on behalf of the client.  
With regard to specific transactions and events, we recommend that Tax Planning services be provided prior to the filing of the return. Please refer to Pre-Audit Tax Planning for a description of Tax Planning services provided in anticipation of an audit.