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Strasburger has experience in nearly all aspects of business and individual tax planning, including the taxation of corporations and their shareholders, partnerships and partners, limited liability companies and their members, and other entities and their owners.  We advise on taxable and tax-free acquisitions, dispositions, mergers, and reorganizations, and real estate, financing, debt restructuring, and leasing activities of businesses. We also advise on bankruptcy tax matters, like-kind exchanges, public and private offerings of securities, joint ventures, venture capital investments, business formations and general business tax matters.

State & Local Tax

We work with clients to minimize state franchise and/or income taxes in various states, frequently accomplished through structuring alternatives and apportionment and allocation methodologies. Strasburger attorneys identify and minimize exposure to state sales and use tax and routinely represent clients regarding applicability of occasional sale exemptions, resale exemptions and collection requirements.

Strasburger tax attorneys review merger, acquisition and divestiture transactions with respect to state and local tax consequences. We also represent clients in state tax audit situations to analyze identified issues, develop audit strategies, negotiate settlements and litigate claims. Strasburger attorneys are also involved in the promotion and drafting of tax legislation that is beneficial to our clients.

Tax Controversy Litigation

Strasburger offers its clients extensive experience in tax controversy and litigation including federal and state civil tax litigation; federal criminal tax litigation, including related white collar crime representation; property tax disputes and litigation; representation of attorneys and accountants in malpractice cases and discipline proceedings; representation of taxpayers before IRS Appeals offices; and representation of taxpayers during civil and criminal IRS examinations.

Property Tax Disputes & Litigation

We represent clients who own commercial tracts of land, including land used for agricultural, industrial, manufacturing and other business purposes. We have significant experience in property tax litigation, particularly arising after an unsuccessful hearing with the administrative review board or after the local appraisal district decides to litigate the review board’s decision. Although our attorneys have substantial experience once these cases reach litigation, we are also equipped to handle the administrative process as well.

International Tax

Strasburger handles a wide range international tax matters, including structuring inbound and outbound business and real estate investments; cross-border mergers, acquisitions and joint ventures; reorganizing and restructuring multinational corporate groups; handling international tax controversies before the IRS and in the courts; advising on information reporting; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, foreign currency transactions, profit repatriations, tax treaty issues and reducing or eliminating U.S. estate and gift tax liability.

The firm’s practice unit leaders are available to answer any questions about Strasburger’s capabilities.  To learn more about this practice area, please contact john.round@strasburger.com.
Tax
OVERVIEW
Strasburger has experience in nearly all aspects of business and individual tax planning, including the taxation of corporations and their shareholders, partnerships and partners, limited liability companies and their members, and other entities and their owners.  We advise on taxable and tax-free acquisitions, dispositions, mergers, and reorganizations, and real estate, financing, debt restructuring, and leasing activities of businesses. We also advise on bankruptcy tax matters, like-kind exchanges, public and private offerings of securities, joint ventures, venture capital investments, business formations and general business tax matters.

State & Local Tax

We work with clients to minimize state franchise and/or income taxes in various states, frequently accomplished through structuring alternatives and apportionment and allocation methodologies. Strasburger attorneys identify and minimize exposure to state sales and use tax and routinely represent clients regarding applicability of occasional sale exemptions, resale exemptions and collection requirements.

Strasburger tax attorneys review merger, acquisition and divestiture transactions with respect to state and local tax consequences. We also represent clients in state tax audit situations to analyze identified issues, develop audit strategies, negotiate settlements and litigate claims. Strasburger attorneys are also involved in the promotion and drafting of tax legislation that is beneficial to our clients.

Tax Controversy Litigation

Strasburger offers its clients extensive experience in tax controversy and litigation including federal and state civil tax litigation; federal criminal tax litigation, including related white collar crime representation; property tax disputes and litigation; representation of attorneys and accountants in malpractice cases and discipline proceedings; representation of taxpayers before IRS Appeals offices; and representation of taxpayers during civil and criminal IRS examinations.

Property Tax Disputes & Litigation

We represent clients who own commercial tracts of land, including land used for agricultural, industrial, manufacturing and other business purposes. We have significant experience in property tax litigation, particularly arising after an unsuccessful hearing with the administrative review board or after the local appraisal district decides to litigate the review board’s decision. Although our attorneys have substantial experience once these cases reach litigation, we are also equipped to handle the administrative process as well.

International Tax

Strasburger handles a wide range international tax matters, including structuring inbound and outbound business and real estate investments; cross-border mergers, acquisitions and joint ventures; reorganizing and restructuring multinational corporate groups; handling international tax controversies before the IRS and in the courts; advising on information reporting; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, foreign currency transactions, profit repatriations, tax treaty issues and reducing or eliminating U.S. estate and gift tax liability.

The firm’s practice unit leaders are available to answer any questions about Strasburger’s capabilities.  To learn more about this practice area, please contact john.round@strasburger.com.

EXPERIENCE

Tax Planning

Handled tax aspects of corporate inversion and restructuring transaction for major international manufacturing group, including obtaining favorable IRS ruling on spin-off necessary to accomplish restructuring.

Assisted with all legal and tax aspects of expansion into an international market for a national home products corporation.

Negotiated and prepared documents to implement significant corporate partnering transaction for major dairy products operation.

Structured and negotiated tax incentive package for a Fortune 500 Company which is presently resulting in an annual tax benefit exceeding $1 million.

Lead tax support on three party sale of $200 million of insurance settlement proceeds, including tax planning and analysis of transaction.

Participated in tax team to plan, structure, and negotiate the tax aspects of large business combination between a partnership and S corporation.

State & Local Tax

Represented many clients before the Texas Comptroller, administrative law judges, and state courts in cases involving disputed tax liabilities or refund claims.

Represented Fortune 500 company with complex property tax disputes involving various appraisal districts and taxing units.

Advised U.S. Big 3 automaker regarding property tax provisions of acquisition agreement.

Advised national food products company regarding the state income and transfer tax consequences of proposed mergers.

Represented several clients in negotiating voluntary disclosure agreements whereby the taxpayer is able to normalize its state tax compliance and reduce its exposure for periods of past non-compliance with state tax laws.

International

Structured offshore start-up venture, involving subpart F issues and estate planning.

Advised regarding the structuring and drafting of intercompany licensing and service agreements between U.S. parent entity and Mexican subsidiaries.

Represented U.S. parent company regarding the acquisition of stock and assets of Mexican businesses, including structuring and planning issues and coordination with foreign tax advisors.

Advised regarding tax planning for compensation of foreign employees of U.S. companies.

Advised client regarding the U.S. tax treatment of foreign CLOs.

Represented client regarding the existence of permanent establishments under various income tax treaties.

Represented client regarding the withholding analysis on various types of payments by foreign businesses made to U.S. companies.