Tax Controversy and Litigation
Reinhart’s Tax Controversy and Litigation group is dedicated to reducing the tax liabilities of Wisconsin-based, national and international businesses. Closely owned companies also benefit from our expert tax advice and our success in a number of landmark tax cases.
We provide cost-effective and practical solutions to our clients' tax and legal challenges. We listen and respond. All of this is reflected in our outstanding record and reputation.
Long, protracted battles with the IRS or the various state revenue agencies can be avoided or minimized through resolution of tax controversies by Reinhart's Tax Controversy and Litigation group. As one of the largest tax groups in Wisconsin, we offer a high level of experience and expertise and have earned a reputation for obtaining significant tax reductions, both in and prior to court.
We use our experience and expertise to effectively resolve tax disputes, resulting in considerable savings to our clients. Our team also works closely with your internal tax departments and other professionals to address a wide variety of tax issues. We have obtained significant tax reductions for our clients, both in and out of court including:
- Civil tax audits and administrative appeals
- Litigation in the United States Tax Court, United States Court of Federal Claims and federal district courts
- Litigation in the Wisconsin Tax Appeals Commission, Wisconsin Court of Appeals, circuit courts and local Boards of Review
- Litigation in other state boards and commissions
- Appeals to numerous federal and state appellate courts
- Criminal tax investigations and litigation
Experience, technical proficiency and knowledge are attributes each Reinhart tax attorney offers. We offer a value-added benefit of having an established and respected track record with the taxing authorities. Our tax attorneys, who have represented taxpayers in a number of landmark tax cases, bring exceptional knowledge and expertise to very specific tax laws and solutions.
Several of our attorneys are former IRS trial attorneys or Wisconsin Department of Revenue officials. Many of our attorneys teach or have taught other tax practitioners at the University of Wisconsin-Milwaukee's Masters of Tax program, Marquette University Law School and countless other tax-related seminars and programs in the United States and Canada. In addition, our attorneys have authored and co-authored tax textbooks, treatises, scholarly articles and publications.
We have handled a wide range of cases with amounts in dispute from thousands to hundreds of millions of dollars. We have addressed many tax issues with the various taxing authorities. Some of the issues that our Tax Controversy and Litigation attorneys have successfully resolved for our clients have included:
- Federal tax
- Mergers, acquisitions and joint ventures
- Corporate reorganizations and conversions
- S corporation, partnership and limited liability company issues
- Tax accounting
- Real estate transactions, including like-kind exchanges
- Executive compensation/fringe benefits, including reasonable compensation issues
- Midco transactions
- Intangibles
- Passive loss
- UPREIT transactions
- Derivatives
- Hobby loss adjustments
- Research and development credit
- Valuation and valuation discount issues
- Health care provider tax issues
- Related party issues
- Consolidated return issues
- Tax-exempt organization disputes
- Payroll tax imposition and responsible person issues
- Ownership succession
- Charitable contributions, including contributions of easements
- Estate tax
- Gift tax
- International tax
- Transfer pricing, including negotiations with authorities of foreign governments
- Taxation of foreign companies with U.S. activities
- Taxation of U.S. companies with foreign activities
- State and local tax
- Income/franchise tax allocation and apportionment
- Special purpose entities
- Mixing bowl transactions
- Sales and use tax
- Income and sales tax nexus including impact on out-of-state businesses
- Property tax valuation
- Property tax exemption
- Property tax issues for tax-exempt health care providers
- Ad valorem and unit valuation tax issues
- Property taxation of utilities, telecommunications and airlines
- Unclaimed property
- Unemployment compensation/worker's compensation
- Real estate transfer fees
- Excise taxes
- Nonfiler negotiations
- Criminal tax