Taxation

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Overview

Businesses and individuals we represent in federal and state taxation matters have long recognized the prudence of planning a tax strategy with the assistance of competent legal counsel. Some of our clients likewise have had occasion to appreciate the value added by legal advisors who have the experience and knowledge base to assist them through federal and state regulatory processes designed to avoid tax controversies in advance, and to have them heard and resolved through formal hearing or settlement processes when they do arise. Still others have leaned heavily on tax litigators who can press cases effectively in the United States Tax Court or federal or state district courts and appellate courts. From our solid grounding of advanced tax educational degrees, years of "inside" employment experience with federal and state taxing authorities, and decades of collective experience as private counsel on all aspects of taxation, our team of tax lawyers fulfill the needs of clients in all possible phases of the tax cycle.

Attorneys

Experience

Our tax lawyers have extensive experience representing a wide variety of taxpayers, both individuals and businesses, including "Fortune 500" companies, engaged in local, national, and/or multinational activities. We work in conjunction with a wide variety of professional contacts and associations including actuarial services, accounting services, and qualified intermediaries to broaden the range of solutions we offer. We also assist clients with seeking changes in policy, regulations and statutes.

State and Local Tax Practice

Our state and local taxation practice is based upon solid years of experience and our detailed knowledge of our rather unique gross receipts and compensating ("use") taxes, personal and corporate income taxes, the various taxes imposed upon the oil, gas, coal, minerals and other industries active within the state, as well as conservation easement tax credit issues, property taxation and excise, liquor, and tobacco taxation. We also have developed a comprehensive knowledge of the constantly evolving set of tax regimes and incentives of importance to our renewable energy clients. We represent clients before the New Mexico Taxation and Revenue Department in all manner of tax disputes including obtaining revenue rulings, preparing protests and claims for refund, and providing representation in formal hearings before the Department's Hearing Officers. We also have experience litigating in the trial and appellate courts of New Mexico.

Federal Tax Practice 

Our federal tax practice covers all stages of the tax cycle for clients, from planning tax strategies to litigating in the U.S. Tax Court or the federal district courts and appellate courts where the need arises. We are also experienced in all phases of the federal tax controversy resolution process beginning with representation in connection with audits through appeals and negotiation of settlements. The diverse range of federal tax issues on which we have represented clients include:

  • ERISA procedures and compliance
  • Deferred compensation issues
  • Tax-free land exchanges
  • Consolidated taxation of related entities
  • Executive compensation tax issues
  • General taxation of business entities chosen or being chosen
  • Mergers, acquisitions and dispositions
  • Exempt, non-profit, or not for profit corporations
  • Partnership taxation
  • Federal taxation relating to Indian tribes and dual taxation issues
  • Taxation issues arising under RMMLF Form 5 mining joint ventures
  • Hobby loss rules
  • Trust, estate and business succession planning
  • Charitable trusts and other wealth transfer planning strategies
  • General and special tax issues and strategies

Multi-Jurisdictional Tax Issues

Our tax lawyers have extensive experience addressing complex and cutting edge constitutional Commerce Clause, due process, and apportionment issues. Such issues frequently arise in the context of multistate, multinational and out-of-state taxpayers, and taxpayers with complex corporate structures.