Federal and State Tax Matters

Businesses in California face some of the highest tax rates in the nation and the world, thus it’s important that companies choose counsel they can trust that is capable of delivering creative, effective tax solutions that support their long-term business and tax planning objectives. Our lawyers are focused on federal tax matters, and advise businesses on business formation and corporate transactions, capital formation and financing, as well as business and treasury operations. We help structure partnerships, limited liability companies and other joint venture arrangements. Our tax team handles federal tax issues in the full complement of transactional corporate tax matters, including mergers and acquisitions, dispositions, spin-offs, internal restructurings and litigation.

Our attorneys work with all branches of Federal and California tax agencies. Our attorneys handle regulatory and administrative matters at the principal federal agencies, including before the IRS and the Departments of the Treasury and Justice.

MJP supports our clients in the IRS examination and appeals processes and, if needed, in tax litigation. Our extensive controversy experience enables us to anticipate and prepare in advance for IRS positions. Additionally, we serve our client’s needs in highly specialized area federal estate tax planning.

Contact our tax team to discuss your problem!

FTB/IRS Tax Liens

If you owe back taxes, the IRS and state agencies gain a tax lien on all your assets after meeting certain statutory requirements. The tax lien attaches to all property and the taxpayer’s rights to real, personal, tangible or intangible property. Once the IRS or a state tax agency has a tax lien on all...

Innocent Spouse Relief

Married taxpayers generally choose to file a joint tax return because of certain tax benefits this filing status confers. If the taxes on that joint income tax return go unpaid, however, both taxpayers are jointly and individually responsible for the tax and any interest or penalty due, even if they later divorce. This is true...

Mergers, Acquisitions and Transactions

We advise buyers and sellers of businesses in a wide variety of situations, from tax free mergers and acquisitions, to strategic, and cash versus stock. We advise a diverse set of clients from buyers or sellers of family businesses, all the way up to complex deals involving multiple parties and millions of dollars. Our firm...

Multi Jurisdiction Tax / California Non-Resident Tax Practice

We often render advice to foreign nationals, U.S. and foreign businesses about the ongoing personal and operational issues facing businesses and individuals regarding California tax nexus, operations and assets in multiple jurisdictions. Today, the world is flatter than ever and the global business and investment community, must consider the tax business and regulatory framework of...

Offer in Compromise

An Offer In Compromise (OIC) is an agreement between a taxpayer and the Internal Revenue Service (IRS) that resolves the taxpayer’s tax liability. The IRS has the authority to settle, or compromise, federal tax liabilities by accepting less than full payment under certain circumstances. The IRS may legally compromise for one of the following reasons:...

Partnerships, LLCs, LLPs and S Corporations

Our practice involves structuring investment and business entities, including the appropriateness of C corporations, S corporations, general and limited partnerships, LLCs, and LLPs. We frequently counsel partners and partnerships on the tax consequences of organizing, operating, and terminating. Our extensive experience in this highly complex and specialized area of the tax law allows us to...

State and Local Taxation

As the capital of California, the 9th largest economy in the world, the Sacramento region is the ideal location for our state and local tax practice because it allows us to connect with the state’s taxing agencies and provides the unique opportunity to practice before these agencies on a daily basis. Against the backdrop of an...

Tax Controversies and Litigation

Tax controversies come in many varieties, from audits to administrative appeals, from trial court to appellate court, from pre-tax disputes to post-tax refund claims. Whether your case involves federal or state, income, gift, excise, sales or property tax; we have the experience and depth to handle your tax controversy with unparalleled effectiveness.We represent individuals and...

Tax Levies

An IRS Tax Levy is a legal seizure of taxpayer’s assets taken in order to satisfy a tax debt.  An IRS Tax Levy can be attached to any property, including bank accounts, real estate and automobiles, but is most frequently applied to bank accounts, securities, wages and even a business’ accounts receivable. The IRS usually...