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Practice Areas :
Tax
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Additional Tax Practices
As a result of opportunities, interest, experience and/or work on public policy matters, Patton Boggs tax lawyers have developed special expertise in certain niche areas of tax law that are not covered in other summaries of our tax practice on our Web site. If you are looking for tax lawyers with a specialized expertise, please call us and we will let you know if we are able to assist you. The following is a short sampling of our expertise and experience:
Section 529 and Tax Incentives for Education
Two of our tax partners are leading experts on tax issues relating to section 529. Working for a bank client, one of our partners developed a prototype state statute for establishing a “qualified state tuition program” under section 529 of the Internal Revenue Code. That prototype statute served as the model used by several of the first states to adopt section 529 plans under which assets could be invested in mutual funds, certificates of deposits and other products offered by the private sector. That partner continues to advise two related entities that are providers under state section 529 programs, including preparing, updating and reviewing their disclosure documents and providing comments to the Internal Revenue Service (IRS) on proposed guidance under section 529. Another tax partner was the primary author of section 529 while working as tax counsel for the U.S. Senate Finance Committee. In addition to the Senate experience, that partner also served as a Member of the Board of the Investment Committee for the Virginia College Savings Plan, a role in which she oversaw the more than 1.8 million accounts and nearly $30 billion of assets under management in the plan.
We have assisted a client in preparing its custodial agreement and disclosure document of Coverdell education savings accounts, traditional IRAs and Roth IRAs.
Environmental Excise Taxes
As an adjunct to the substantial public policy work that the firm undertook in connection with the phase out of ozone-depleting chemicals (ODCs), our tax lawyers have developed special expertise on environmental excise taxes. One of our partners, who is a former chair to the American Bar Association’s Tax Section’s Environmental Taxes Committee, has advised a trade association and at least four chemical companies on compliance with environmental excise taxes. When the rules for the ODC tax were initially developed, we interfaced with the IRS and the Environmental Protection Agency (EPA), which was developing rules for the phase out of the chemicals, in a successful effort to get the two agencies to adopt rules that were as consistent as the enacting legislation permitted. Recently, we used constitutional arguments on behalf of a chemical company to convince the IRS to withdraw a proposed assessment of more than $100 million of unpaid environmental excise taxes.
Excise Tax Exemptions and Credits
Patton Boggs assisted a trade association of blood collector organizations in obtaining exemptions from certain fuel and communications excise tax. As a result of that effort, the firm’s tax lawyers have developed a special expertise in the esoteric world of obtaining exemptions, credits and refunds of excise taxes. Recently, the firm’s tax lawyers have applied that expertise in helping companies understand how various alternative energy tax incentives would work and in helping investment banking firms understand how lumber companies were able to claim tax credits for “black liquor.”
Tax Issues for Fund Managers
Patton Boggs has special expertise in addressing the many tax issues faced by fund managers, including issues relating to deferral and section 409A, cross-border issues and compensatory warrants and partnership interests. We have helped guide a large hedge fund manager through a series of complex issues. Through our public policy work for the Managed Funds Association, we remain in close contact with other tax lawyers who advise fund managers and we stay abreast of the latest developments on issues of importance to hedge fund and private equity fund managers, including capital gains for carried interests and section 409A deferral issues.
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practice AREA BREAKING NEWS
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TAX, BENEFITS AND NONPROFIT ORGANIZATIONS CLIENT ALERT: American Taxpayer Relief Act of 2012 Impact on Charitable Giving and Exempt Organizations
January 8, 2013
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (9th Edition)
January 1, 2013
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (7th Edition)
December 31, 2012
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (8th Edition)
December 31, 2012
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (6th Edition)
December 28, 2012
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (5th Edition)
December 20, 2012
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (4th Edition)
December 19, 2012
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Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (3rd Edition)
December 17, 2012
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TAX, BENEFITS AND NONPROFIT ORGANIZATIONS CLIENT ALERT: Treasury Issues Binding Guidance on Medical Device Excise Tax
December 10, 2012
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