Bracewell tax lawyers help clients integrate business objectives with the requirements of federal tax laws. We help clients:

• Address the tax consequences of mergers and acquisitions
• Structure and execute all forms of energy transactions and financings
• Determine the effects of public stock and debt offerings, offerings of unit investment trusts and rights offerings on tax obligations
• Structure liquidations, spin-offs, recapitalizations and transfers of ownership for maximum tax advantage
• Use limited liability companies, partnerships, subchapter S corporations and other tax-efficient structures in the formation of small businesses
• Develop and implement tax planning strategies at all stages of their development
• Maintain the federal 501(c)(3) classification available to tax-exempt organizations

In energy transactions and work in all areas touching on energy. This includes oil and gas partnerships, master limited partnerships, acquisitions, dispositions and restructuring power plants and projects, the development, structuring and monetization of tax benefits of renewable energy projects such as wind, biomass and geothermal and energy transmission and distribution.

In real estate transactions, we advise both developers and investors on like-kind exchanges, partnership formations, dissolutions, distributions and transfers of interest. Our lawyers frequently work with real estate investment trusts (REITs) on matters such as the purchase and sale of assets, mergers and acquisitions, public and private offerings of debt and equity securities, and various partnership structures.

We assist employers in maintaining the tax advantages of executive compensation agreements, employee benefit plans and non-profit organizational structures. We help business clients design and implement qualified and non-qualified benefit plans and compensation arrangements, including profit-sharing plans, pension plans, 401(k) plans, employee stock ownership plans, deferred compensation plans, stock option plans, and cafeteria and welfare benefit plans. We help clients prevent and resolve problems or conflicts in benefit plan structures that may arise from a merger or acquisition.

A key concern for tax-exempt entities is maintenance of federal 501(c)(3) classification. We review and revise organizational charters and bylaws so that they conform to tax code requirements. We help clients ensure proper filing of Form 990 (reporting on programs and finances) and Form 1023 (application for exemption). When tax-exempt clients are involved in business transactions, particularly with taxable organizations, we help them address potential effects on their non-taxable status. In some case, assist in establishing new corporate structures or leasing arrangements to handle unrelated business income tax issues.

In the face of Internal Revenue Service audits, we help clients determine the most appropriate course of action, whether that means litigation or a negotiated settlement. We are thoroughly familiar with the procedures required to reduce IRS penalties, obtain IRS private letter rulings, respond to IRS demands for documents, and challenge administrative summonses. Bracewell tax lawyers appear on behalf of clients before the United States Supreme Court, the U.S. Courts of Appeals and District Courts, the U.S. Tax Court, and Texas and other state courts.