Tax

Overview

Honigman’s Tax practice group assists clients in achieving their goals by developing and implementing practical and creative tax strategies to address the challenges of a complex and quickly evolving regulatory environment. We are experienced in addressing varied and sophisticated tax issues. 

A major focus of our Tax practice includes the structuring of transactions, from both a domestic and international perspective. Our tax attorneys assist with a wide variety of complex concerns, including matters involving corporations, partnerships, and limited liability companies (LLC); exchanges and restructurings; executive compensation; mortgage-backed securities and real estate mortgage investment conduits (REMIC); real estate investment trusts (REIT); real estate transactions; state and multi-state taxes; reallocation issues among commonly controlled entities; cross-border transactions; estate planning; New Markets Tax Credits programs; low-income housing and historic rehabilitation credits; and energy credits. Our clients include individuals, publicly traded and privately held C corporations, subchapter S corporations, partnerships, LLCs, syndications, tax-exempt organizations, tax-qualified plans, and trade associations. These clients are technology companies, financial institutions, oil and gas developers, real estate developers, offshore captive insurance companies, private equity firms, and manufacturers, among others. 

Our Tax attorneys counsel clients directly and assist other attorneys at the firm in providing a full array of tax law services in such areas as:

  • Choice of entity
  • Structuring transactions
  • Securities offerings
  • Individual tax advice
  • Lobbying and participation in the tax legislative process
  • Tax credit transactions
  • Advice concerning return preparation
  • Business, estate, and succession planning

We also frequently represent clients before federal and state tax authorities, administrative tribunals, and the courts. 

To keep abreast of potential changes in tax laws or rules that may affect our clients, we monitor the development of tax laws through contacts with Congressional tax staffs, the U.S. Treasury Department, and the Internal Revenue Service, as well as through study of digital information services and numerous tax publications.  

Representative Matters

  • Represented condominium developer in partnership recapitalization involving redemption of an equity partner, admission of hedge fund as new equity partner, and refinancing of project debt
  • Advised client with respect to sale of manufacturing company to a private equity fund, with a tax-free rollover of a portion of seller equity interests
  • Represented developer in structuring and negotiating sale of low-income housing tax credits to equity investor
  • Counseled restaurant franchisee in restructuring ownership and entity structure of various operating companies to achieve tax, corporate, and other efficiencies
  • Represented client in partnership workout involving restructuring of distressed debt and buyout of partner’s equity position
  • Advised foreign partner of tax implications under the Foreign Investment in Real Property Tax Act (FIRPTA) of recapitalizing partnership owning U.S. real estate
  • Counseled publicly traded REIT on requirements for maintaining REIT status in connection with public offering of securities
  • Represented issuers with respect to tax issues arising in transactions involving offerings of public and private debt

News & Resources

News

Press Releases

Events

  • The Present State of Tax Reform Legislation, Webinar
    October 21, 2021
  • Limited Market Properties Should Not Limit Your Valuations, Institute for Professionals in Taxation Annual Conference, Traverse City, MI
    June 12-15, 2016
  • Michigan Update, Institute for Professionals in Taxation Annual Conference, Traverse City, MI
    June 12-15, 2016
  • How to Resolve Your State Tax Dispute, Institute for Professionals in Taxation Annual Conference, Traverse City, MI
    June 12-15, 2016
  • Michigan, Indiana, and Ohio Property Tax Update, Institute for Professionals in Taxation Annual Conference, Traverse City, MI
    June 12-15, 2016
  • Michigan Corporate Income Tax: Understanding Unitary Business Filing & Apportionment, Michigan Chamber of Commerce, Novi, MI
    May 12, 2016
  • The Nuts and Bolts of Obtaining a Private Letter Ruling, Oakland County Bar Association Tax Committee
    April 19, 2016
  • Building Success as a Tax Practitioner, State Bar of Michigan Tax Section - Young Tax Lawyers Committee
    March 22, 2016
  • Property Tax Update on Key States, 2016 ABA/IPT Advanced Property Tax Seminar, New Orleans, LA
    March 3-4, 2016
  • Personal Property Tax Update, Michigan Chamber of Commerce, Webinar
    Ongoing series
  • Preparing for Audit Challenge & Controversy, COST 2016 SALT Basics School, Grapevine, TX
    January 2016
  • Best Practice in Tax Administration, 25th Annual Ohio Tax Conference, Columbus, OH
    January 27, 2016
  • Top Ten State Tax Cases with Significant Impact on State Tax Policy, 25th Annual Ohio Tax Conference, Columbus, OH
    January 27, 2016
  • Not Since 1992 Has the U.S. Supreme Court Been So Active in State & Local Taxes ... Intricacies of Wynne, CMX & DMA Decisions & Impact on State & Local Taxes, 25th Annual Ohio Tax Conference, Columbus, OH
    January 27, 2016
  • Regional Update ... Tax Advice for Companies Doing Business in Michigan and Pennsylvania, 25th Annual Ohio Tax Conference, Columbus, OH
    January 26, 2016
  • What's Happening Everywhere Today? Michigan SALT Update, 34th Institute on State and Local Taxation, New York University: School of Professional Studies, New York, NY
    December 2015
  • Nexus - A Review of Where We Are and Where We Are (Or May Be) Going, NYU 34th Institute on State and Local Taxation, New York, NY
    December 2015
  • Your Guide to Michigan Tax Resolution, The Michigan Association of Certified Public Accountants (MICPA), Webinar
    December 17, 2015
  • State and Multistate Tax Audits, Interstate Tax Planning Conference, Chicago, IL
    December 2015
  • Foreign Goodwill and Going Concern Value under the Proposed Section 367 Regulations, State Bar of Michigan Taxation Section
    December 9, 2015
  • What's Happened Since 2014, Michigan Tax Conference, The Michigan Association of Certified Public Accountants (MICPA), Novi, MI
    November 2015
  • Analyzing Case Law, Court Opinion and Your Applications, Michigan Tax Conference, Novi, MI
    November 2015
  • Nexus: A Multistate Update on Taxation of Services, 22nd Annual Paul J. Hartman State and Local Tax Forum, Vanderbilt University Law School, Nashville, TN
    October 2015
  • Michigan Update, COST Midwest Regional Tax Seminar, St. Louis, MO
    August 18, 2015
  • Multistate Cases, Issues and Policy Matters, Council on State Taxation Regional Tax Conference
    August 2015
  • Michigan Corporate Income Tax, Michigan Chamber of Commerce, Novi, MI
    July 9, 2015
  • Preparing for Audit Challenge & Controversy, COST 2015 Intermediate/Advanced State Income Tax Schools, Atlanta, GA
    May 21, 2015
  • State Bar of Michigan's 28th Annual Tax Conference, Taxation Section of the State Bar of Michigan in cooperation with the Institute of Continuing Legal Education, Plymouth, MI
    May 21, 2015
  • Brand New! Michigan’s Offer in Compromise Program – Critical Opportunities, CPE Mega Conference, The Michigan Association of Certified Public Accountants (MICPA), Sterling Heights, MI
    May 14, 2015
  • Economic Presence Nexus Does Not Negate P.L. 86-272: A Re-examination of Protected and Unprotected Activities, Advanced Tax Seminars Presented by the American Bar Association and Institute for Professionals in Taxation, New Orleans, LA
    March 2015
  • Preparing for Audit Challenge & Controversy, COST 2015 SALT Basics School, Atlanta, GA
    January 30, 2015
  • Regional Update … Tax Advice for Companies Doing Business in Michigan & Pennsylvania, 24th Annual Ohio Tax Conference, Columbus, OH
    January 2015
  • The Nuts and Bolts of Obtaining a Private Letter Ruling, Federal Income Tax Committee, Taxation Section of the State Bar of Michigan
    January 15, 2015
  • State and Multistate Tax Audits, Interstate Tax Corporation, Chicago, IL
    December 12, 2014
  • Taxing Cross Country – What You Need to Know, Michigan Tax Conference, Novi, MI
    November 5, 2014
  • State Taxation of Online Transactions, Michigan Tax Conference
    November 2014
  • How to Request a Private Letter Ruling, Advanced Tax Quarterly, American Institute of CPAs (AICPA), Webinar
    October 30, 2014
  • Multistate Sales Tax Nexus Developments, 18th Annual Deloitte Center for Multistate Taxation
    June 2014
  • Select Issues in Tax-Free Distributions Under Section 355, Federal Income Tax Committee of the State Bar of Michigan Tax Section
    March 6, 2014
  • Bitcoin Tax Issues, New York State Society of CPAs, Webinar
    February 6, 2014
  • Update on Michigan Taxes, 23rd Annual Ohio Tax Conference, Columbus, OH
    January 2014
  • Michigan Supreme Court Tax Cases, Michigan Tax Conference, Novi, MI
    November 2013
  • Nexus What's New for 2013, Paul J. Hartman State and Local Tax Forum
    October 2013
  • Certain Aspects of the Federal Income Tax Treatment of Virtual Currencies, State Bar of Michigan Taxation Section’s Business Entities Committee
    October 11, 2013
  • Working with State Historic Preservation Offices and the National Park Service, Novogradac Historic Tax Credit Conference, Detroit, MI
    September 2013
  • Understanding Canada-U.S. Taxation, Third Annual Workshop, Toronto, ON
    June 6-7, 2013
  • Gross Receipts Taxes, Institute for Professionals in Taxation: Advanced Income Tax School
    June 2013
  • Upcoming Multistate Tax Issues, Council on State Taxation Regional Tax Conference, Detroit, MI
    May 2013
  • Apportionment Issues, Advanced Tax Seminars Presented by the American Bar Association and Institute for Professionals in Taxation
    March 2013
  • Regional Update ... Tax Advice for Companies Doing Business in Michigan and Pennsylvania, 22nd Annual Ohio Tax Conference, Columbus, OH
    January 30, 2013
  • SBT and MBT Lingering Issues, Institute for Professionals in Taxation: Michigan One-Day Tax Seminar, Southfield, MI
    September 2012
  • Federal Rehabilitation Tax Credits and Tenant Demands, Novogradac Historic Tax Credit Conference, Louisville, KY
    September 2012
  • Michigan Sales and Use Tax Developments, Michigan Association of Certified Public Accountants (MACPA) State Tax Forum, Novi, MI
    June 2012
  • The New CIT, Michigan Chamber of Commerce, Webinar
    June 2012
  • Real Property Tax -- Your Window to Saving Money is Closing Soon!, Webinar, Michigan Association of Certified Public Accountants (MACPA)
    February 2012
  • State Taxation of Online Transactions, 21st Annual Ohio Tax Conference, Columbus, OH
    January 2012
  • Michigan One-Day Tax Seminar, The Institute for Professionals in Taxation in cooperation with the Michigan Department of Treasury, Taylor, MI
    September 2011
  • Judicial Doctrines Every Tax Lawyer Should Know, Business Entities Committee, Taxation Section, State Bar of Michigan, Honigman Miller Schwartz and Cohn LLP, Bloomfield Hills, MI
    March 24, 2011
  • Sales Factor - Shifting to Multiple Weighted or Single Factor Sales Apportionment Factors and Shifting from Cost of Performance Sourcing to Market-Based Sourcing, Advanced Tax Seminars Presented by the American Bar Association and Institute for Professionals in Taxation, New Orleans, LA
    March 2011
  • Tax Risk Management, Including the Implications of Schedule UTP (Uncertain Tax Positions), Tax Accrual Workpapers, Attorney Work Product and Privilege Rules after the Deloitte Case and Economic Substance Rules, KPMG Automotive Tax Share Forum at North American International Auto Show, Detroit, MI
    January 13, 2011
  • Review of Recent US Federal Tax (IRS) Audits, Cayman Captive Forum, Insurance Managers Association of Cayman
    December 2010
  • How to Make Projects Financeable Using Public Incentives - and How to Live with the "Aftermath", International Shopping Center Law Conference, Hollywood, FL
    November 2010
  • Partnership Mergers and Divisions & Carried Interest Legislation Update, ICLE After Hours Tax Law Series
    October 5, 2010
  • Recent Legislative and Administrative Developments Affecting Business Entities and Their Owners, Business Entities Committee Meeting, Taxation Section, State Bar of Michigan
    October 1, 2010
  • Minimizing Taxes in Workout, Restructuring, and Debt Modification Transactions, State Bar of Michigan 23rd Annual Tax Conference
    May 20, 2010
  • Minimizing Taxes in Workout, Restructuring, and Debt Modification Transactions, 23rd Annual Tax Conference, State Bar of Michigan
    May 20, 2010
  • Top Ten Tax Issues in Structuring Low-Income Housing Credit Transactions, Michigan Conference on Affordable Housing
    April 26, 2010
  • International Tax Planning, Compliance and Audit Issues Facing Companies and Individuals: The Inbound and Outbound Perspectives, 22nd Annual Tax Conference, Taxation Section, State Bar of Michigan, Plymouth, MI
    April 29, 2009
  • Current Trends in Canada: Cross-Border Lending Transactions, Holding Companies and Income Tax Treaties, Automation Alley
    December 2008
  • Real vs. Personal Property, Michigan Tax Conference, Novi, MI
    November 2008
  • MACPA Construction Industry Conference, Novi, MI
    October 30, 2008
  • Current Trends in Europe: Emerging Markets, Holding Companies, and Supply Chain Management, Automation Alley
    June 1, 2008
  • Choice of Entity Issues in the International Context, State Bar of Michigan Tax Conference
    May 2008
  • International Tax - Demystifying Europe and China, After Hours Tax Law Series, Institute of Continuing Legal Education
    January 2008
  • 2008 Michigan Unemployment Insurance Update, 2008 Michigan Tax Conference, Michigan Association of Certified Public Accountants
    2008
  • Constitutional Aspects of the New Michigan Business Tax, Michigan Tax Conference
    November 2007
  • Practical Aspects of Working With the Unemployment Insurance Agency - 2007 State Tax Forum, Michigan Association of Certified Public Accountants
    2007
  • Tax and Other Inducements for the Development of Real Estate, American College of Real Estate Lawyers Annual Conference
    2006
  • Strategies For Handling A Michigan Unemployment Insurance Agency Audit - 2006 Michigan Tax Workshop, Michigan Association of Certified Public Accountants
    2006
  • Indiana Tax Conference 2006 – Michigan Developments, Indiana Chamber of Commerce
    2006
  • Michigan Tax Update, Tax Executives Institute Inc., Detroit Chapter
    2005

Publications

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