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Federal Taxation
Team Leader
U.S. Congress regularly makes significant changes in federal tax law, and in recent years has enacted complex changes to laws governing corporations. Understanding and adapting to this evolving legal landscape is critical to the success of any business. Whyte Hirschboeck Dudek S.C.’s Federal Taxation Team is committed to rigorous study of any changes in both tax and corporate law so that we can help clients avoid potential tax pitfalls in their businesses, as well as capitalize on unique opportunities. The team is composed of high-caliber attorneys who bring dual expertise in corporate and tax law to our clients. Some team members hold accounting degrees and are CPAs; others have MBAs in tax.
 
WHD’s experience encompasses the following principal areas related to federal tax:

 

  • Corporate structures
  • Reorganizations
  • Mergers and acquisitions
  • Executive compensation
  • Employee ownership stake
  • IRS audits
  • IRS administrative appeals
  • Tax litigation
  • Succession planning

 

Federal Tax Controversy
Tax audits (civil and criminal) by the IRS are unfortunately a cost of “doing business.” Our Federal Tax Controversy Team consists of seasoned tax attorneys who have represented hundreds of clients in tax audits and administrative appeals, and have represented clients in more than 40 trials in the federal tax courts—achieving significant concessions from the IRS and victories in court.
 
The team (which includes former IRS and U.S. Department of Justice (DOJ) attorneys) specializes in representing multinational and domestic companies, their executives, their owners, other individuals, and estates in large, complex federal civil and criminal tax audits.
 
The team also leverages its unique blend of combined tax and litigation experience to assist clients and their non-tax or non-litigation counsel as co-counsel in matters before the U.S. Tax Court, in state and federal court and with state and federal tax agencies. The team represents clients in all phases of criminal and civil tax proceedings, including voluntary disclosures, sensitive audits and examinations, IRS appeals, summons enforcement, search warrants, grand jury subpoenas, negotiated resolutions with the IRS and DOJ, trials in federal district court and the U.S. Tax Court, sentencings and appellate litigation.
 
WHD is one of a few law firms in the Midwest that has prevailed in the U.S. Tax Court, multiple times in the Seventh Circuit Court of Appeals, the U.S. Court of Federal Claims, Wisconsin Tax Appeals Commission and Wisconsin Circuit Court.
 
Click here to review the resolution of selected tax cases by our Federal Tax Controversy Team.
 
Federal Tax Planning
From a tax planning perspective, so many business activities—from corporate transactions to employee compensation to long-term and estate planning—have significant tax implications. That’s why, at WHD, corporate law and tax law are integrated pursuits. The Federal Tax Planning Team specializes in representing multinational and domestic companies, their executives, their owners, other individuals and estates in large and complex business transactions. Team members know and provide insights to our “deal” attorneys, many of whom are also tax attorneys, to minimize any adverse tax impact or maximize any possible tax impact.

Our Approach

In the tax audit and appeals process before the IRS, we leverage our experience and expertise in advancing our clients’ business interests. We also advise clients on their business activities in a way that advocates for both the best business decisions and the best tax strategies—whether it’s a sale transaction, a reorganization, an executive compensation plan or many other actions. In this manner, we help our clients optimize the tax implications of any given transaction or execute the best business transactions for tax purposes.