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Practice/Industry Group Overview
Our Reportable Transactions Services team takes a proactive and practical approach to dealing with the complex web of regulations that require disclosure of tax shelters-or potentially abusive tax avoidance transactions. The current disclosure rules, while more coherent than earlier versions, still require careful analysis and interpretation, particularly in view of significant new penalties for failure to comply.
Our team has designed and implemented systems that help clients ensure compliance with the reportable transaction disclosure rules on a cost-effective basis. We offer an alternative to expensive, off-the-shelf compliance "packages" sold by other service providers. Our extensive experience lets us target situations and issues where there are significant disclosure risks.
We provide independent, timely, and cost-effective reviews of both proposed and executed transactions to determine whether disclosure is required. We work together with clients to find an overall solution for a potentially reportable transaction -- one that takes into account their existing corporate risk minimization policies. We provide responsible advice that takes into account penalty protection and privilege alternatives.
In fact, you might say that we "wrote the book" on reportable transactions. Members of our team co-authored BNA Tax Management Portfolio 798, Tax Shelters and often participate in cutting-edge forums on tax shelter policy. One of our team members was a primary author of the final tax shelter regulations.
Leadership in Action
Reportable Transactions/Tax Shelter Compliance
Monitorship under DOJ Agreement
Client: One of the world's largest financial institutions.
Type of Matter: Implementation of quality control procedures for certain types of transactions, often involving complex tax strategies, under an agreement with the Department of Justice.
Our Client's Challenge: Our client entered into an agreement with the Department of Justice concerning its participation in certain types of transactions, which often involve complex tax strategies. Pursuant to the agreement our client needed to put in place and follow a number of controls and procedures.
The Goal: To work with the client as a monitor on behalf of the DOJ to ensure compliance.
Our Strategy: Working closely with the client, we reviewed its procedures and also designed workable internal protocols that will help ensure that the terms of the agreement are being followed.
Results: The client has agreed to institute the vast majority of the recommendations provided by Baker Hostetler over the course of the monitorship.
About Our Tax Team
With a team of more than 80 lawyers -- many of whom have served as senior government tax advisors and have received substantial leadership recognition within the legal profession -- Baker Hostetler's national tax practice offers unsurpassed resources to our clients. We can handle any tax planning matter or tax controversy at the state, federal or international level, and have the insight and experience to make the Tax Code work to our clients' advantage.
About Baker Hostetler
Baker Hostetler lawyers help clients establish, maintain and protect market-leading positions across the United States and around the world. We offer clients the strength of 600+ lawyers in a full range of practices, a unique geographic platform including both the coasts and the center of the country, a deep knowledge of industry issues and a 90-year track record of excellence and achievement.
For more information about our Reportable Transactions practice, contact:
National Contacts
Jeffrey Paravano
202.861.1770
jparavano@bakerlaw.com
Melinda Reynolds
216.861.7097
mreynolds@bakerlaw.com
Cincinnati
William Appleton
513.929.3403
wappleton@bakerlaw.com
Cleveland
Melinda Reynolds
216.861.7097
mreynolds@bakerlaw.com
Columbus
Edward J. Bernert
614.462.2687
ebernert@bakerlaw.com
Costa Mesa
George Mooradian
714.966.8800
gmooradian@bakerlaw.com
Denver
Raymond L. Sutton, Jr.
303.764.4103
rsutton@bakerlaw.com
Houston
Lisa Pennington
713.646.1303
lpennington@bakerlaw.com
Los Angeles
Neil Carrey
310.442.8835
ncarrey@bakerlaw.com
New York
Paul P. Eyre
212.589.4210
peyre@bakerlaw.com
Orlando
G. Thomas Ball
407.649.4004
tball@bakerlaw.com
Washington, DC
David J. Fischer
202.861.1712
dfischer@bakerlaw.com
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