Tax

Representing Businesses and Individuals in Tax Law Matters

Tax

Representing Businesses and Individuals in Tax Law Matters

Overview

The Tax Practice Group at Rath, Young & Pignatelli approaches each client’s tax matters as if its attorneys were members of the client’s internal tax and finance team. Our goal in every engagement is to understand the client’s business objectives and structure solutions that allow tax laws to support those objectives.

Our tax attorneys advise individuals, closely held businesses and multinational companies on federal, state, and local tax matters, combining technical depth with practical, business-focused judgment. From planning and compliance to audits, disputes, appeals, and litigation, we provide trusted counsel grounded in decades of experience.

State and Local Tax

Our state and local tax (“SALT”) practice represents a wide range of business clients from Fortune 500 companies to mid-size businesses in assisting them with tax audits, administrative disputes and appeals, court litigation, tax planning, and legislative advocacy. Our SALT professionals provide superior service to clients by keeping abreast of state tax policy issues from across the country while focusing on matters in the New England states, with a particular focus on New Hampshire and Vermont.

We serve as authors and speakers in the state tax field, including as the reporters for New Hampshire and Vermont developments for the Council on State Taxation (“COST”) in Washington D.C.

Our SALT professionals also co-founded the New England State and Local Tax Forum in 2012, which is a non-profit organization created to promote state tax education on significant SALT developments from across the nation with a particular focus on New England. (see www.nesaltforum.org).

Our SALT team works closely with the firm’s government relations group, RYP Granite Strategies, to achieve legislative solutions for our clients when administrative and judicial resolutions are not favorable.  We have been successful in working to change tax laws when they do not represent good tax policy or unfairly impact our clients.

We work hard to resolve disputes in a manner that avoids litigation and therefore most efficiently allows our clients to focus on their core businesses. When litigation is necessary, our tax litigation team has successfully resolved matters through state and federal court systems.

Federal Tax

Our federal tax attorneys advise a wide range of clients with respect to choice of entity issues, efficient structuring of business transactions, tax implications from mergers and acquisitions, real estate transactions, and business tax credits and incentives. We also have deep experience structuring business relationships that are subject to the federal partnership tax rules, including crafting tax allocation mechanisms that bring the highest after tax value to all partners.

A substantial portion of our federal tax practice involves working closely with RYP’s Energy Group in advising clients across the country in development of solar, wind, hydropower, biomass and synthetic, and other alternative and renewable fuel projects that qualify for federal tax credits under Sections 45Y and 48E of the Internal Revenue Code. We provide advice on structuring energy projects to be eligible for federal tax credits, as well as advice to both purchasers and sellers of tax credits generated under Sections 45, 45Y, 48, and 48E. Finally, we help clients navigate some of the hurdles for energy projects introduced under the One Big Beautiful Bill Act. 

Tax Legislation and Public Policy

We have extensive experience securing tax law objectives for clients before the legislative process at both the federal and state levels. The Tax Practice Group works closely with its government relations group, RYP Granite Strategies, monitor and resolve tax matters of importance to our client groups.