Tax

The days of bartering goods and services with the government have long passed, and with them the era of simple tax laws. The intricacies of today’s taxation system demand specialists who spend their days cracking the IRS code.

Bodman tax specialists counsel clients directly and assist other attorneys in providing complete legal services. Tax considerations have become so pervasive in business transactions that interaction between our Tax Practice Group and other practice groups is a way of life.

Our extensive resources allow us to serve the tax-planning and representation needs of a client with an integrated team of attorney specialists in federal, state and local tax matters. We assist C corporations, S corporations, general partnerships, limited partnerships, limited liability companies, limited liability partnerships, foundations, trusts, and individuals.

In addition to corporate tax work, we have long represented non-profit organizations, including churches and other religious institutions, hospitals, educational and charitable organizations, and grantmaking foundations. We counsel non-profits on general tax planning matters as well as general business transaction and management issues, allowing the nonprofits to focus on their mission: providing educational, cultural, medical and civic services to those who need them most.

Our Services:

Our Tax Practice Group provides the following services:

• Domestic and International Corporate Tax. We have extensive experience in all aspects of corporate tax, both in the United States and internationally, including:
  • Acquisitions: taxable and non-taxable
  • Separations
  • Redemptions and liquidations
  • Recapitalizations
  • C corporation tax planning
  • S corporation tax planning
  • Formation and structure
  • Use of disregarded entities
  • Consolidated tax returns
  • International tax planning including cross border issues
  • IRS and state tax litigation at all levels
  • Corporate bankruptcy
  • Personal holding companies
  • Accounting issues
  • Private letter ruling requests

• Partnerships and LLC’s. We advise clients on all areas of partnership and limited liability company law and tax issues, including:
  • Formation, operations and liquidation of partnerships and LLCs
  • Operating agreements
  • Special allocations
  • Ownership and transfer of property
  • Sales of entity interests
  • LLC business structures and groups of entities
  • Combinations and divisions of entities
  • Tax return issues
• Tax-Exempt and Charitable Organizations. The Bodman Tax Practice Group has significant experience in all aspects of tax-exempt and charitable organization tax matters, including matters related to:
  • Private foundations
  • Public charities
  • Community foundations
  • Professional and trade associations
  • Art and cultural institutions
  • Hospitals and health care organizations
  • Colleges and secondary schools
  • Social and civic groups
  • Religious organizations
  • Obtaining and maintaining tax-exempt status
  • Corporate governance
  • Director and officer liability
  • Unrelated business taxable income
  • Excess business holdings
  • Intermediate sanctions
  • Dissolution and liquidation
  • Tax return issues
• State and Local Tax. We advise clients in all aspects of state and local taxation, including:
  • Michigan Business Tax
  • Sales and use tax
  • Income tax
  • Real property tax
  • Personal property tax
• Estate and Gift Tax. Tax Practice Group attorneys have extensive experience in all aspects of estate and gift tax planning, including:
  • Estate planning
  • Estate administration
  • Probate
  • Lifetime gifting
  • Grantor Retained Annuity Trusts (GRATs)
  • Family LLCs
  • Trust disputes
• Tax Litigation. We have successfully litigated federal, state and local tax disputes, including: 
  • United States Tax Court matters
  • Michigan Tax Tribunal matters
  • Internal Revenue Service administrative matters
  • Michigan Department of Treasury administrative matters
  • Federal, state and local Appellate courts matters
• Tax Credit Transactions and Like-Kind Exchanges. The Bodman Tax Practice Group has structured many tax credit and like-kind exchange transactions, including:
  • Federal low-income housing credits
  • Federal and state historic tax credits
  • New Markets tax credits
  • Brownfield redevelopment tax credits

Representative Matters:

Numerous clients have retained us to structure real and personal property transactions to achieve like-kind exchange tax treatment.

We have helped many private foundations and public charities obtain and maintain tax-exempt status and minimize unrelated business taxable income.

We represented a large financial institution in structuring transactions to obtain federal low-income housing tax credits, federal rehabilitation tax credits, federal geothermal tax credits, Michigan Business Tax credits and state Brownfield tax credits.

A concrete manufacturing company turned to us to structure the sale of its business to obtain optimum state and federal tax consequences.

We represented a mortgage lending/servicing operation in negotiations with the Internal Revenue Service to obtain significant income tax refunds.

Bodman tax specialists helped a private foundation form a public/private partnership that provided a $50 million grant to the Detroit Riverfront Conservancy.

We assisted a nonprofit in its involvement with a public/private partnership that partnered with the U.S. Department of Education to create a national after-school program benefiting inner-city children.

We helped a private foundation structure and fund the acquisition and renovation of an abandoned warehouse in Flint, Michigan, which is now home to a public arts facility.

We helped a private foundation and the Grand Traverse Regional Land Conservancy complete the first phase of the acquisition of more than 6,000 acres of sensitive dune and wetlands property with nearly two miles of Lake Michigan frontage, with conservation easements granted to the Michigan Land Trust.

We represented a public charity in an inquiry initiated by the United States Senate Finance Committee.

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