Taxation
Whyte Hirschboeck Dudek S.C.'s Taxation Team brings extensive experience in tax law to their clients.
 
Our attorneys regularly represent clients in federal, state and local income, franchise, sales, and property tax planning and dispute resolution, including issues involving multi-state taxation, nexus and related matters. The team also includes seasoned attorneys with experience defending taxpayers in criminal tax matters.
 
Many of our tax lawyers are also trained as accountants. They work closely with lawyers in our corporate transactions and business law areas to develop and implement optimal tax planning strategies for complex corporate transactions such as acquisitions, mergers, divestitures and other reorganizations. Several of our tax lawyers have in-depth experience in the taxation of S corporations, limited liability companies, partnerships and similar "pass-through" entities.
 
This team is experienced in the full range of services for large and mid-sized companies including executive compensation and compensation arrangements such as stock appreciation and phantom stock plans, stock option programs for corporate employees and tax deferred exchanges of real estate.
 
In addition, our attorneys represent tax-exempt entities of varying sizes including both public charities and private foundations on a broad range of income tax matters and in securing and maintaining tax-exempt status.

Our Approach

We keep abreast of changes in the law and industry trends in order to advise our clients regarding developments that affect their business. We are committed to a tailored approach to representation that considers the goals of the client and relates them to the intricacies of tax law in order to develop the best strategy in each situation.

Representative Engagements

Members of the Taxation Team have:
  • Advised both buyers and sellers of businesses on tax-advantageous structuring of merger and acquisition transactions, both taxable and tax-deferred, providing tax opinions and obtaining private IRS rulings where required
  • Advised business clients in all areas of income tax planning and structuring, including tax planning involving S corporations and other pass-through entities, such as limited liability companies
  • Devised optimal structures for reorganizations and recapitalizations of S corporations, to permit tax-advantaged distributions to shareholders
  • Successfully defended a $25 million tax case involving write-up of intangible assets
  • Devised a corporate recapitalization resulting in savings of $20 million in estate taxes
  • Successfully defended a $6 million tax case involving an attempt by the IRS to impose a penalty tax for unwarranted accumulation of earnings, obtaining a complete concession by the IRS
  • Successfully negotiated numerous offers in compromise of delinquent taxes with the IRS and the Wisconsin Department of Revenue
  • Successfully resolved cases at the U.S. Tax Court, U.S. District Court, Wisconsin Tax Appeals Commission, Wisconsin Court of Appeals and Wisconsin Supreme Court
  • Provided national technical support and review with respect to § 403(b) tax sheltered annuities and § 457 nonqualified deferred compensation plans
  • Served as adjunct faculty in the graduate tax program at the University of Wisconsin-Milwaukee School of Business

Attorneys

Paralegals

Assistant - Taxation

Jamie L. Schlieckau Assistant - Taxation Milwaukee jschlieckau@whdlaw.com