Practices & Industries

Tax

Attorneys in Parker Poe's Tax Practice Group represent clients in sophisticated U.S. Federal and state tax matters and tax controversies. Our tax attorneys advise clients of the tax implications of a broad spectrum of transactions. In addition, we help clients navigate the tax ramifications of Employee Benefit plans as well as the management of Estate Planning and Trusts. The depth and experience of our practice is bolstered by our attorneys' prior experiences at Big Four public accounting firms and the Internal Revenue Service.

The attorneys in Parker Poe's Tax Practice Group regularly represent clients with planning, structuring, negotiating and implementing transactions to yield the most efficient U.S. Federal and state tax consequences. Our tax attorneys work closely with other Parker Poe attorneys in Banking & Finance, Public Finance, Real Estate and Commercial Development, Securities, Mergers & Acquisitions and International Business to ensure a "no-surprises" result. We have particular experience in the automotive, banking, biotechnology, equipment rental, franchising, grocery, manufacturing, real estate and retail industries.

Experience Highlights

Corporate Mergers and Acquisitions – Our attorneys work closely with the Firm's corporate clients with tax-free and taxable mergers and acquisitions. We have represented buyers and sellers in tax-free Section 368 reorganizations and Section 338(h)(10) deemed asset acquisitions. In addition to complicated mergers & acquisitions, Parker Poe attorneys have experience with spin-off transactions under Section 355.

Joint Ventures – We regularly represent clients in the negotiation and documentation of joint venture transactions. These transactions frequently take the form of limited liability companies and limited partnerships, and attorneys in the Tax Practice Group regularly prepare LLC operating agreements and limited partnership agreements. We work with institutional investors and promoters in their participation in joint venture transactions, which include shopping center developments, mixed-use real estate developments and international manufacturing companies.

Tax Controversies – The Tax Practice Group represents clients in controversies with the U.S. Internal Revenue Service and state tax authorities in such matters as audits, federal tax liens and administrative appeals. Attorneys in the Tax Practice Group are qualified to practice before the Internal Revenue Service and the U.S. Tax Court and we have experience as clerks in the U.S. Tax Court and the U.S. Federal District Court. The Tax Practice Group also includes a former attorney-advisor in the Internal Revenue Service's Office of Chief Counsel.

Section 1031 Like Kind Exchanges – Attorneys in the Tax Practice Group have an in-depth knowledge of Section 1031 like-kind exchanges. We have experience with reverse exchanges and build-to-suit exchanges. While much of our Section 1031 work involves real estate transactions, we also work with Section 1031 exchanges of corporate aircraft and leased equipment.

Partnership Taxation – A comprehensive knowledge of partnership taxation is important with the increasing popularity of limited liability companies as a form of doing business. Our attorneys regularly advise clients as to the tax implications of these arrangements, which often are complex and include many references to the Internal Revenue Code without explanation. We have advised clients on "disguised sales" of contributed property, divisions and mergers of partnerships under Section 708 and dispositions of partnership interests.

International Taxation – Parker Poe represents many foreign corporate and non-corporate clients. The Tax Practice Group regularly advises these clients as to U.S. Federal and state taxation of inbound investments and transactions. Similarly, the Tax Practice Group advises U.S. clients as to the U.S. Federal and state taxation of outbound investments and transactions in foreign countries. We have experience advising foreign nationals of the U.S. tax consequences of their employment in the U.S., and we have advised U.S. citizens of the tax consequences of working outside of the U.S.

S Corporations – Many of our closely held clients are organized as Subchapter S corporations. Our attorneys advise clients in the formation and ongoing operations of S corporations.

Banking and Finance Transactions – Our tax attorneys represent financial institutions and borrowers in the tax aspects of a variety of lending transactions. We advise borrowers in the U.S. Federal and state taxation of private and public debt financings. Our tax attorneys regularly work with the Firm's Banking Group in their role as servicer's counsel in CMBS transactions, which regularly implicate the REMIC Federal tax rules under Section 860G.

Tax-Exempt Organizations – The Tax Practice Group represents tax-exempt and charitable organizations. We represent several Section 501(c)(3) organizations as well as other organizations exempt from tax under Section 501(c). Our tax attorneys have experience advising tax-exempt organizations about the U.S. Federal unrelated business income tax (UBIT). We have represented tax-exempt organizations in restructuring transactions such as mergers and conversions of tax-exempt entities to other types of Section 501(c) organizations.

Name/Title Phone V-Card Email

Andrea C. Chomakos

Partner

 t 704.335.9087 V-Card Email

James N. Greene III

Partner

 t 704.335.9896 V-Card Email

Lloyd G. Jackson III

Associate

 t 704.335.6633 V-Card Email

Michael Larsen

Partner

 t 843.727.6311 V-Card Email

Steven B. Long

Partner

 t 919.835.4683 V-Card Email

P. Scott Manning

Special Counsel

 t 704.335.9018 V-Card Email

Erica R. Messimer

Associate

 t 704.335.9039 V-Card Email

George H. Pretty II

Partner

 t 704.335.9073 V-Card Email

Ray N. Stevens

Partner

 t 803.253.8654 V-Card Email

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