Tax Advisory
Focused technical analysis for complex or one-time tax issues, from restructurings and method changes to IRS disputes and deal structure.
Overview
Some tax questions do not fit inside the annual compliance cycle. A reorganization, a change in accounting method, a significant transaction, or a dispute with the IRS calls for focused research and a clear written answer. Our tax advisory work addresses these specific issues. We define the question, analyze the facts against the Internal Revenue Code, regulations, and relevant guidance, and explain the options and their risks in plain terms so you can make an informed decision.
Tax advisory is project-based and issue-specific, which is what distinguishes it from our tax planning work. Planning is the recurring, year-round review of structure, timing, and compensation. Advisory steps in when a particular situation needs deeper technical analysis, documentation of a position, or representation in a controversy. The two often connect, since ongoing planning frequently surfaces the issues that become advisory projects.
How We Help With Tax Advisory
Restructurings and Reorganizations
Analyzing the tax effects of mergers, spin-offs, entity conversions, and ownership changes, and helping structure the steps to reduce unintended tax consequences where the rules allow.
Accounting Method Changes
Evaluating whether current tax accounting methods are permissible and favorable, and helping prepare requests to change methods for items such as revenue recognition, inventory, or depreciation.
Tax Research Memos
Written analysis of specific tax questions that documents the facts, applicable law, and reasoning behind a position, useful for decision-making and supporting the position later.
IRS Controversy
Representing clients in complex examinations, preparing written protests, and working through IRS administrative appeals and penalty matters when a dispute goes beyond routine notice responses.
Transaction Tax Structuring
Advising on the tax treatment of acquisitions and sales, including asset versus stock structures, elections, purchase price allocation, and the tax effects of earnouts and rollover equity.
Specialized Tax Issues
Analysis of less common issues such as cancellation of debt income, net operating loss use, related-party transactions, and international information reporting questions as they arise during the year.
Challenges We Help You Address
- ✓A significant transaction with unclear or high-stakes tax consequences
- ✓Tax accounting methods that may no longer be the right fit
- ✓An IRS examination that has moved beyond routine correspondence
- ✓Positions that need written support in case they are later questioned
- ✓Reorganizing ownership or entities without triggering unexpected tax
Frequently Asked Questions
What does a tax advisor do that a tax preparer does not?
A tax preparer focuses on reporting what has already happened on accurate returns. A tax advisor analyzes specific issues before or as decisions are made, such as how to structure a transaction, whether to change an accounting method, or how to respond to an IRS challenge. Advisory work involves research, judgment about risk, and written analysis that supports the position taken.
What is a tax accounting method change?
A tax accounting method determines when income and deductions are reported, such as cash versus accrual, inventory methods, or depreciation of certain assets. Changing a method generally requires IRS consent, which may be automatic for certain changes or require advance approval for others. A method change can produce a one-time adjustment to account for the difference between the old and new methods.
What is a tax research memo?
A tax research memo is a written analysis of a specific tax question. It lays out the relevant facts, identifies the applicable law and guidance, applies that law to the facts, and reaches a conclusion with an assessment of the strength of the position. Memos help decision-makers understand risk and provide documentation if the position is later examined.
When should I get help with an IRS audit?
It is generally best to involve a CPA as soon as you receive an examination notice, before responding substantively. Early involvement helps frame information requests, organize documentation, and identify issues before they become disputed adjustments. If an examination results in proposed changes you disagree with, a representative can help prepare a written protest and work through the IRS administrative appeals process.
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