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General Practice

Tax Issues

Tax Practice

We provide individuals, businesses, trusts and estates, and tax-exempt organizations with creative tax planning in a responsive and cost efficient manner. We regularly work with members of the business counseling and real estate groups in structuring businesses and transactions in a manner thatĀ helps our clients achieve their business objectives while at the same time, minimizing the impact of state, federal, and, in some cases, foreign taxes. We also work with members of our estate planning group counseling individuals, families, and entrepreneurs on business succession and wealth transfer issues.

Business Taxation

We take an interdisciplinary approach to assisting clients in structuring transactions that meet business objectives in the most tax-effective manner. Our tax lawyers function as an integral part of the corporate and business counseling group and are often brought in to work on transactions in the early stages to not only avoid tax problems, but to ensure that all tax planning opportunities are explored. We serve as a key component in our transactional group's team approach to many transactions, including the creation, sale, purchase and dissolution of business and real estate entities, partnership issues, pension planning, employee benefits and executive compensation.

Real Estate Taxation

Members of our tax practice group also work closely with our real estate clients in structuring complex real estate deals and transactions, including like-kind exchanges, installment sales, loan restructurings, and foreclosures. We also regularly represent commercial real estate owners before state taxing authorities on seeking reductions in real property assessments. While we are willing an able to advance a client's position at the Tax Tribunal or higher appellate levels, we are often able to save our clients legal fees by obtaining a reduction of a client's assessment through negotiations with the local Property Assessor.

Lender Representation In Restructing Of Real Estate Loans

We also handle the tax aspects of work-outs, and represent lenders in the restructuring of real estate loans. Whether in transactions or in litigation support, our tax attorneys provide our clients with a full understanding of tax consequences and help to develop creative solutions seeking tax results.

Estate And Trust Taxation

Without proper planning, transfer taxes can deprive surviving family members of a significant portion of the estate a client has created by a lifetime of hard work and sacrifice. Our tax and estate planning groups work together to create estate plans and gifting programs designed to meet our client's goals of transferring wealth to future generations in the most tax-efficient manner. To achieve this objective, our tax attorneys thoroughly analyze the income, estate, gift, and generation-skipping transfer tax implications of transfers and work with our estate planners to creatively structure estate plans and lifetime gifting programs. For those who did not plan adequately plan during life, tax planning is still possible. Our tax attorneys work with our estate and trust administration attorneys to review post-mortem tax planning opportunities available to increase the amount passing to a deceased client's surviving family.

Tax-Exempt And Charitable Entities

Our tax practice is not limited to for-profit entities. We also counsel tax-exempt entities on qualification, formation, and operation issues. We obtain tax-exempt status rulings from the IRS, sometimes obtaining favorable tax-exempt rulings in situations where exempt status is not readily evident, and registering tax-exempt organizations at the state level. We also advise tax-exempt entities on UBTI issues and structuring joint ventures with for-profit entities. On the personal planning side, we work with our estate planning group in creating and obtaining recognition of tax-exempt status for private foundations. Our tax lawyers advise clients in connection with numerous charitable giving techniques, and act as advisers to major national and international charities as well.

Tax Controversy And Litigation

We regularly represent clients in IRS audits at each stage of the audit and appeal process, beginning with the audit at the local IRS office through the internal IRS appeals process. While we are often able to resolve issues at the IRS level, we will, when necessary, advance our client's position at the lower court (U.S. Tax Court, District Court, or Court of Claims) and appellate court levels


Our web site is intended to be used for general information only. The purpose of our site is to inform visitors of the nature of legal services offered by Michigan Attorney Gerald F. Chefalo. The information contained herein is not intended as specific legal advise. We caution that use of our web site or attempting to contact our office via e-mail will not establish an attorney-client relationship. An attorney-client relationship is established by the express written consent of Gerald F. Chefalo by means of a retainer agreement.