TAX PLANNING AND CONTROVERSIES

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Tax Planning:

Dan Baucum has the comprehensive knowledge and in-depth experience to serve as tax counsel in business purchases, sales, reorganizations, start-ups and split-ups. He can assist you with choosing the right business structure for your domestic and international business or investments where taxes are an integral part of the transaction. With decades of both government and private practice experience, Mr. Baucum provides tax planning related to LLCs, limited partnerships, S corporations, and other business entities including C corporations. He presents innovative tax solutions to your business and investment challenges in line with your goals. He also seamlessly combines tax structuring with asset and estate preservation and planning for closely held business owners.

For example, Mr. Baucum offers advice regarding the following matters:

  • Structuring acquisitions and dispositions of operating companies and investments
  • Drafting and organizing straightforward and complex limited liability company and limited partnership agreements
  • Structuring carried interests and profits interests
  • Structuring shareholder, member, and partner admissions and buyouts
  • Converting S corporations into limited liability companies
  • Structuring business startups, closely held businesses, private equity funds, and investments
  • Structuring tax-free corporate acquisitions and split-ups
  • Obtaining IRS private letter rulings for proposed transactions
  • Structuring straightforward and complex like-kind exchanges of real estate
  • Analyzing and fine-tuning bankruptcy restructurings, liquidations, and workouts
  • Structuring cross border transactions into Canada and from Canada and Europe into the U.S.
  • Reporting transactions involving non-U.S. persons investing in U.S.
  • Forming, operating, and planning for tax-exempt entities and trade associations
  • Succession and preservation planning for high net-worth individuals and families
Tax Controversies:

Dan Baucum is by your side when facing high-stakes audits or tax appeals of an unfavorable audit. Mr. Baucum brings a thorough understanding of both IRS practice and federal tax issues that can arise during IRS audits and appeals. With significant IRS Chief Counsel experience, Mr. Baucum represents clients in requesting IRS private letter rulings for complex federal tax issues and proposed business transactions. He also assists in requesting IRS Chief Counsel’s National Office relief for inadvertently terminated tax elections.

Mr. Baucum successfully settles tax disputes for individuals and businesses of all sizes. Whether engaged at the beginning of a tax controversy, or called in after other attempts have failed, Mr. Baucum fights hard to identify significant issues and develop strategies to achieve the client’s objectives. Mr. Baucum works to negotiate a resolution at the administrative level to avoid the additional cost and distraction that can accompany tax litigation. If litigation is inevitable, Mr. Baucum has the experience and know how to position the matter for litigation and present the case to achieve the best result.

Consulting Tax Counsel:

Dan Baucum works with lawyers, accountants, and tax professionals as a consultant and team member assisting with a wide variety of complex federal tax issues. He also assists other tax professionals with IRS rulings and conferences at the IRS National Office and uses his IRS practice insight during high-stakes tax audits, IRS Appeals, and litigation. Mr. Baucum has served as a testifying expert in federal tax matters, including areas such as partnership taxation, IRS practice and procedure, and business structuring and governance.