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

  • James H. Combs is quoted in the Crain’s Detroit Business article “Rules murky on Opportunity Zones for cannabis business”
    (October 13, 2019)
     
  • Lynn A. Gandhi is profiled and quoted in the State Tax Notes article "State Tax Spotlight on Lynn Gandhi"
    (March 7, 2016)
     
  • June Summers Haas is quoted in the Law360 article “Mich. Court Says Online Services Exempt From Use Tax”
    (November 2, 2015)
     
  • James H. Combs is quoted in the Crain’s Detroit Business article “Tax extenders package again left hanging”
    (October 25, 2015)
     
  • Ilan Napchan and David E. Koropp are mentioned in the American Lawyer article “Dentons Keeps Growing, Plus More Lateral Moves”
    (October 11, 2015)
     
  • Ilan Napchan and David E. Koropp are featured in the Law360 article “Honigman Adds 2 Partners To Tax, Litigation Practices”
    (October 2, 2015)
     
  • Lynn A. Gandhi is profiled in The Wayne Lawyer article “Attorney strives to help tax law keep pace with changing economies”
    (July 24, 2015)
     
  • James H. Combs is featured in the DBusiness article “Honigman Partner Named to Children’s Hospital Board”
    (July 2, 2015)
     
  • James H. Combs is featured in a Q&A in the Bloomberg article “Tax Efficiency of Notes Depends on Structure, Lawyer Combs Says”
    (May 28, 2015)
     
  • Lynn A. Gandhi is profiled in the Wayne Law article “Wayne Law alumna strives to help tax law keep pace with changing economies”
    (April 30, 2015)
     
  • Richard S. Soble is featured in the DBusiness article “Honigman Partner Named Tops In Client Service”
    (April 29, 2015)
     
  • Lynn A. Gandhi is highlighted in the State Tax Notes article “Person of the Year”
    (December 12, 2014)
     
  • Lynn A. Gandhi is mentioned as the counsel for Lorillard Tobacco Co. in the Law360 article “Mich. Appeals Court Remands Lorillard’s $1.2M Tax Suit”
    (September 17, 2014)
     
  • Crain's Detroit Business/Honigman Survey Results: "Biz to Snyder, Bernero: Cut MBT, but don't increase the deficit"
    (September 27, 2010)
     
  • Seventy-eight Honigman attorneys mentioned in The Detroit Legal News for their honors by Best Lawyers
    (August 24, 2010)
     
  • Honigman’s Michael A. Indenbaum mentioned in Detroit Free Press article, “Tax-exempt groups could be abusing status, expert says”
    (August 22, 2010)
     
  • June Summers Haas quoted in Crain’s Detroit Business article “CAPITOL BRIEFINGS: Bill would prevent years of back tax filings”
    (March 24, 2010)
     
  • Lynn A. Gandhi and June Summers Haas featured in the Detroit Legal News and Ingham County Legal News article “Honigman partners June Summers Haas and Lynn A. Gandhi speak at National Tax Seminar”
    (March 24, 2010)
     
  • Lynn A. Gandhi quoted in MiBiz article "Battery industry charges ahead. Will markets follow?"
    (March 15, 2010)
     
  • Article published by James H. Combs, Journal of Taxation and Regulation of Financial Institutions, "Potential Impact of the American Jobs Creation Act Straddle Rules," Vol. 19, No. 5, May/June 2006
    (June 1, 2006)
     
  • June Summers Haas quoted in, "SBT Reform Draws Immediate Yeas, Nays," Lansing/Jackson Business Review, February 3-9, 2005
    (February 9, 2005)
     
  • June Summers Haas quoted in, "Proposed Tax Shift To Service, Insurance Cos. Spurs Debate," Lansing/Jackson Business Review, February 3-9, 2005
    (February 9, 2005)
     
  • June Summers Haas quoted in "Governor Calls For Massive Change In SBT Proposal," Mlive.com
    (January 31, 2005)
     
    Lansing Jackson Business Review
  • June Summers Haas quoted in "Business Assessing Granholm's Plans For SBT Overhaul," Crain's Detroit Business, January 31, 2005
    (January 31, 2005)
     
  • Honigman Tax Attorneys Alan Valade and June Summers Haas Quoted in Rick Haglund Article, "Column: Fixing SBT All A Matter of Taste" on Mlive.com
    (June 7, 2004)
     

Press Releases

Events

  • Limited Market Properties Should Not Limit Your Valuations, 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
  • How to Resolve Your State Tax Dispute, 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
  • 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
  • Top Ten State Tax Cases with Significant Impact on State Tax Policy, 25th Annual Ohio Tax Conference, Columbus, OH
    January 27, 2016
  • Best Practice in Tax Administration, 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
  • 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
  • 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
  • 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
  • Analyzing Case Law, Court Opinion and Your Applications, Michigan Tax Conference, Novi, MI
    November 2015
  • What's Happened Since 2014, Michigan Tax Conference, The Michigan Association of Certified Public Accountants (MICPA), 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
  • Top Ten Cases, 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
  • Round-Up of Select Recent State and Local Tax Cases, 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
  • 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
  • State and Multistate Tax Audits, Advanced Interstate, Interstate Tax Corporation, Dallas, TX
    November 21, 2014
  • Ethics and Managing the Sales and Use Tax Function, Advanced Interstate, Interstate Tax Corporation, Washington, D.C.
    November 18, 2014
  • Preparing for Audits and Litigation, Advanced Interstate, Interstate Tax Corporation, Washington, D.C.
    November 11, 2014
  • Taxing Cross Country – What You Need to Know, Michigan Tax Conference, Novi, MI
    November 5, 2014
  • Unclaimed Property - Not a Tax, but Feels Like One!, 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
  • State Tax Controversies and Litigation, IPT Sales and Use Tax Symposium, Washington, D.C.
    September 21-24, 2014
  • State and Multistate Audits, Advanced Interstate, Interstate Tax Corporation, San Francisco, CA
    June 27, 2014
  • Multistate Sales Tax Nexus Developments, 18th Annual Deloitte Center for Multistate Taxation
    June 2014
  • Fundamental Aspects of Jurisdiction and Nexus, Advanced Interstate, Interstate Tax Corporation, New York, NY
    June 9, 2014
  • Ethical and Procedural Issues in Managing the State Income Tax Function, Advanced Interstate, Interstate Tax Corporation, Miami, FL
    May 6, 2014
  • Ethics, COST Income Tax Conference, Colorado Springs, CO
    April 27-30, 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
  • Fundamental Aspects of Jurisdiction and Nexus, Advanced Interstate, Interstate Tax Corporation, Chicago, IL
    December 9, 2013
  • Managing Audits and Litigation, Advanced Interstate, Interstate Tax Corporation, Washington, D.C.
    November 19, 2013
  • 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
  • Multistate Tax Audits, Advanced Interstate, Interstate Tax Corporation, Dallas, TX
    October 25, 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
  • Ethical and Procedural Issues in Managing the State Income Tax Function, Advanced Interstate, Interstate Tax Corporation, Miami, FL
    May 15, 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
  • Ethical and Procedural Issues in Managing the State Income Tax Function, Advanced Interstate, Interstate Tax Corporation, Miami, FL
    May 16, 2012
  • The Ins and Outs of Unclaimed Property, State Bar of Michigan Annual Tax Conference, Plymouth, MI
    May 1, 2012
  • Legislation and Litigation Update in the Eastern United States, COST 2012 Sales Tax Conference, Austin, TX
    March 5, 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
  • 22nd Annual Tax Conference, presented by State Bar of Michigan Taxation Section, The Inn at St. John's 
    April 29, 2009
  • 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
  • 2008 Michigan Unemployment Insurance Update, 2008 Michigan Tax Conference, Michigan Association of Certified Public Accountants
    2008
  • International Tax - Demystifying Europe and China, After Hours Tax Law Series, Institute of Continuing Legal Education
    January 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
  • Current Estate and Gift Tax Valuation Cases, IRS Administrative Developments and Legislation, Michigan Association of Certified Public Accountants
    2000
  • Current Issues in Michigan Taxation and Case Law Update, Michigan Tax Workshop, Michigan Association of Certified Public Accountants
    1999
  • Michigan Sales, Use and Single Business Taxes, Advanced Sales and Use Tax Conference, Interstate Tax Corporation
    1999
  • Michigan and Federal Tax Incentives, Brownfield Redevelopment in Michigan, Consumers Renaissance Development Corporation
    1998
  • Automotive Dealers and Suppliers Conference, State Tax Update, Michigan Association of Certified Public Accountants
    1998
  • S Corporation Update, Michigan Association of Certified Public Accountants
    1995
  • Michigan's Single Business Tax and Recent Value-Added Tax Proposals in Texas and Florida, Tax Executives Institute
    1992
  • Real Estate Tax Planning & Appeals, Michigan Institute for Continuing Legal Education Seminar
    1991
  • Tax Planning for the Business Lawyer, Michigan Institute for Continuing Legal Education Seminar
    1991

Publications