Federal Tax

On transactional matters, the Federal Tax Group works closely with the Firm's Business, Energy, and Real Estate Practice Groups to deliver coordinated and seamless advice that responds to the overall business and personal objectives of our clients. These transactions, including mergers, acquisitions, joint ventures, commercial financing, and business succession planning, frequently involve complex federal, state, and international tax issues.

We pride ourselves in creating practical, tax-efficient structures to meet our client's needs. We also represent both individuals and businesses in tax controversies and disputes before all levels of the Internal Revenue Service, the United States Tax Court, and the Federal District Courts.

REPRESENTATIVE MATTER

Demutualization and Recapitalization Work

Recent work for Savings Bank of Maine involved complex and novel tax issues.

 

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SUCCESS

Favorable Private Letter Rulings

Recently received two favorable private letter rulings from the IRS.

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SUCCESS

501(c)(3) Status Granted

Assisted a New Hampshire public charity seeking 501(c)(3) status.

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SUCCESS

IRS Appeal on Compensation

Successfully represented a corporate client in appealing IRS executive compensation determination.

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SUCCESS

Fox Island Winds, LLC

Representation in the development of an innovative initiative which included the receipt of federal production tax credits.

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NMTC Financing

For a Community Development Entity (CDE) client, we closed a $12M New Market Tax Credit (NMTC) pooled loan fund. This is one NMTC transaction in a series of financings we are handling under the federal and state new markets programs.

Areas of Expertise

Business Transactions

Pierce Atwood's Federal Tax Group works closely with the Business Group to structure transactions in the most tax-efficient manner possible.  Tax considerations often determine the form and the viability of contemplated transactions.  Accordingly, members of our group become involved in transactional matters at the outset, learning and understanding the client's business, structure, and balance sheet to achieve the client's objectives.  Members of the Federal Tax Group regularly advise clients on the federal, state, and international tax aspects of corporate reorganizations, mergers, acquisitions, spin-offs and other dispositions, joint ventures, financings, and restructurings. 

Renewable Energy
Over the past several years, renewable energy projects have frequently been driven by federal and state tax credits and other tax incentives. Members of the Federal Tax Group regularly work with the Energy Practice Group and the Renewables Team to structure and develop renewable energy projects, including wind, solar, and biomass projects, to achieve our client's objectives in the most tax-efficient manner possible. Often this involves the syndication or monetization of tax credits. We have expertise and experience with all tax aspects of renewable energy projects, including investment tax credits, production tax credits, new markets tax credits, and the Section 1603 cash grant program.
Tax Controversies

Members of the Federal Tax Group represent clients in tax controversy matters, including trial litigation and IRS audits and appeals.  We regularly advise clients during the audit process by assisting in responses to IRS requests, developing strategies to identify and address issues.  Many concerns are resolved at the audit level, but when they are not, we obtain successful resolutions at the appeal level or before the United States Tax Court or the Federal District Courts.  We work closely with our Litigation Group in many controversies so that our clients have the benefit of both experienced tax lawyers and innovative litigators.

Tax Credit Financing & Syndication

In today’s tight credit market tax credits are often an important piece of financing a project.  Pierce Atwood’s attorneys have experience with tax credit financing and syndication, including new markets tax credits, historic rehabilitation tax credits, low-income housing tax credits, and renewable energy tax credits.  At times, these credits can be combined to reduce the net cost of a project.  For example, a mill renovation may qualify for historic rehabilitation tax credits, new markets tax credits, and even renewable energy tax credits if the project includes a rooftop solar installation.  

Tax Exempt Organizations
Along with our Trusts and Estates Group, we provide advice and counsel to tax-exempt organizations regarding all organizational and operational aspects of obtaining and maintaining federal tax exemption and public charity status. We also counsel clients and plan for the taxation of unrelated business activities. We help clients comply with all applicable tax rules, including structuring compensation arrangements to meet deferred compensation rules and intermediate sanctions regulations. We regularly prepare exemption applications. In conjunction with members of our State and Local Tax Group, we also provide guidance regarding state tax exemptions, including exemptions from sales tax and property tax.