Taxation
The attorneys of Stites & Harbison’s Tax Group assist a variety of clients (corporations, estates, exempt organizations, individuals, limited liability companies, partnerships, trusts and universities) with tax planning and litigation on the federal, state and local levels. The attorneys include a former United States Tax Court law clerk and a former attorney for the Internal Revenue Service’s Office of Chief Counsel (Tax Court). Many of the attorneys have master-of-law degrees in taxation.
The attorneys of Stites & Harbison’s Tax Group routinely serve clients in a range of matters that include:
- Aircraft Acquisition and Leasing
- Aircraft Fractional Interests
- Alternative and Renewable Energy Tax Planning
- Business Acquisitions
- Business Contracts
- Business Formations
- Business Liquidations
- Business Mergers
- Business Planning
- Business Restructurings
- Cafeteria Plans
- Captive Insurance Companies
- Charitable Contributions
- Corporate Spin-Offs, Split-Offs and Split-Ups
- Corporate Tax
- Divorce Tax Planning
- Elder Law
- Employee Benefits
- Employee Plans Voluntary Compliance Program
- Employee v. Independent Contractor
- ERISA (fiduciary, prohibited transactions, etc.)
- ESOPs
- Estate & Gift Planning
- Estate & Gift Tax (including tax return preparation)
- Executive Compensation
- Federal Excise Taxes
- Fiduciary Income Tax Returns (preparation and planning)
- FIRPTA (foreign investment in US real property)
- Georgia Income Tax
- Georgia Sales & Use Tax
- Georgia Tax Litigation
- Incentive Stock Options
- Income Tax Planning
- Individual Tax
- Interest Rate Swaps
- International Tax Planning (Inbound and Outbound)
- Investment Fund Formation (Structuring, LP or LLC Agreements, PPMs)
- IRS Appeals
- IRS Audits
- IRS Ruling Requests
- Kentucky Income Tax
- Kentucky Inheritance Tax
- Kentucky Retirement System
- Kentucky Sales & Use Tax
- Kentucky Tax Litigation
- LLC Operating Agreements
- Local Taxes
- Low-Income Housing Credit
- Medicaid Planning
- Multistate Tax
- New Markets Tax Credits
- Nonqualified Deferred Compensation
- Nonqualified Stock Options
- Partnership Tax
- Penalty Abatement
- Pre-Nuptial and Post-Nuptial Agreements
- Private Foundations
- Probate (including litigation)
- Purchase & Sale of Assets
- Qualified Opportunity Zones
- Qualified Retirement Plans (401(k) and defined benefit)
- Regulated Futures Contracts
- REITs and RICs
- REMIC Defeasance Tax Opinions
- Restricted Stock Plans
- S Corporations
- Shareholders’ Buy-Sell Agreements
- State Tax Incentives (including PILOT incentives)
- Stock Purchase Agreements
- Stock Redemption Agreements
- Tax Court Litigation
- Tax Exempt Organizations (Formation, Exemption Applications, Intermediate Sanctions, and IRS Audits)
- Taxfree Exchanges (Code Section 1031)
- Tax Opinions
- Tax Return Review and Analysis
- Tax Settlements
- Tax Treaty Analysis and Planning
- Tennessee Business Tax
- Tennessee Franchise and Excise Tax
- Tennessee Indebtedness Tax
- Tennessee Miscellaneous Taxes
- Tennessee Sales & Use Tax
- Tennessee Tax Litigation
- Transfer Pricing
- Trust Administration (including litigation)
- Trust Agreements
- Unrelated Business Income Tax
- Voting Trusts
- Welfare Benefits (health, disability and life insurance)
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"Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one's taxes."
—J. Learned Hand, Helvering v. Gregory, 69 F.2d 809, 810 (2d Cir. 1934), citing United States v. Isham, 84 U.S. (17 Wall.) 496, 506, 21 L.Ed 728 (1873).
Bert Wolf Named Stites & Harbison’s Memphis Office Executive Member
MEMPHIS, Tenn.—Stites & Harbison, PLLC attorney Herbert B. Wolf Jr. (Bert) has been named Office Executive Member for the Memphis, Tenn., office.
IFLR1000 Honors Stites & Harbison and James C. Seiffert
LOUISVILLE, Ky.—IFLR1000 has announced that Stites & Harbison, PLLC and attorney James C. Seiffert have been honored in IFLR1000 United States for 2020.
Retirement Plan Excessive Fee Litigation is on the Rise
Retirement plan sponsors and other fiduciaries are required by ERISA to discharge their duties with the “care, skill, prudence, and diligence” under the circumstances as would a prudent man. This means, among other things, fiduciaries should ensure that all fees paid by the plan for recordkeeping and investment management services are competitive and reasonable.
$5 Billion of New Market Tax Credits in Search of High Impact Projects
It is anticipated that the Community Development Financial Institutions Fund (“CDFI”) will announce $5 billion in New Markets Tax Credits (“NMTC”) allocation awards within the next several weeks.
CARES Act – Relief for Small Businesses
On Friday, March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act of 2020 (the “CARES Act” or “Act”) passed and was signed – it is the largest economic aid package in United States history.
Tax Provisions of the CARES Act – What You Need to Know
Late in the evening on Wednesday, March 25, 2020, the United States Senate unanimously passed H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act or the “CARES Act”. The CARES Act is expected to be approved by a vote in the House and be signed by President Trump on Friday, March 27, 2020.
Stites & Harbison elects three attorneys to Management Committee
LOUISVILLE, Ky.—Stites & Harbison, PLLC recently elected three members to the firm’s six-member Management Committee, replacing three attorneys who completed their terms of service. The new committee members are attorneys Erika Barnes, Carol Dan Browning and Richard Wehrle.
Congress Passes Extension for New Markets Tax Credits Program, Increases Allocation by $1.5 Billion
When some people hear the phrase New Markets Tax Credits, they might think of an obscure tax incentive. However, other people, those who deal with the program or have been directly impacted by it, think of something completely different. These individuals think of a hydroelectric generating facility found on the Kentucky River, a new health and science building at a small college in Berea that offers students a debt-free education, a brand new state-of-the-art YMCA in West Louisville that offers increased community services to society’s most vulnerable, or a Winchester facility that manufactures bio-degradable plastic items while employing those desperately in need.
Dan Douglass and Bill Joseph Recognized in 2020 Georgia Super Lawyers
ATLANTA—Stites & Harbison, PLLC attorneys Dan Douglass and Bill Joseph were recently honored in the 2020 Georgia Super Lawyers magazine.
IRS Finalizes Opportunity Zones Regulations
On December 19, 2019, nearly two years to the day since the enactment of the Opportunity Zones legislation (Pub. L 115-97), the U.S. Treasury Department and Internal Revenue Service issued 544 pages of anticipated final regulations on the Opportunity Zones program.
Bill Joseph recognized in Georgia Trend's 2019 Legal Elite
ATLANTA—Georgia Trend magazine has selected Stites & Harbison, PLLC attorney William M. (Bill) Joseph as one of its 2019 Legal Elite. This is the sixth time Joseph has earned the Legal Elite honor.
Time to Consider Investments in Operating Businesses in Opportunity Zones
Opportunity Zones are depicted as transformative tools created to stimulate employment and achieve economic growth in distressed low-income communities. Like a public-private partnership, eligible taxpayers are entitled to significant tax incentives in exchange for investing unrealized capital gains in Opportunity Zones.