Tax

Baker Botts Tax lawyers offer individuals and corporations a wealth of experience in addressing complex tax needs. Our Tax lawyers work closely with other transactional lawyers to develop plans and structures that help our clients with their business objectives, while minimizing the impact of state, federal and international taxes.

We are experienced at providing the requisite tax advice to clients in transactions involving investments in projects, mergers, acquisitions, restructurings and financings, including asset leasing.

We have particular experience advising clients in global tax services in the following industries:

Our work in tax planning cuts across the spectrum of business activities and investments. For example, Baker Botts Tax lawyers have been actively involved with master limited partnerships (MLPs) since the early 1980s, and our experience in this area is nationally renowned. We have represented both issuers and underwriters in MLP initial public offerings, as well as sellers and purchasers in merger and acquisition transactions.

We also have a substantial practice in employee benefits and executive compensation, assisting clients with all aspects of compensation and benefit plans and programs under the Internal Revenue Code and ERISA, and with the myriad of legal issues that impact employee benefits under federal labor and securities laws and state laws.

Our team is also experienced in every facet of tax controversy and tax litigation matters, and includes former senior IRS management and IRS lawyers. We are nationally recognized for our experience in representing taxpayers in estate and gift tax controversies, especially those involving difficult-to-value assets, such as interests in closely held businesses, family limited partnerships and limited liability companies. We have received favorable taxpayer outcomes in some of the most significant estate and gift tax controversies in the last twenty years.

Our Tax lawyers have extensive experience in advising and representing clients on state and local tax matters, including income tax, franchise tax, property tax and sales tax, whether the issues arise in states where our offices are located, or elsewhere in the United States.

In addition, we counsel individuals, families and entrepreneurs on wealth transfer, succession planning and other estate tax issues.

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Interactions with the IRS

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State Bar of Texas 47th Annual Advanced Estate Planning and Probate

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Panel Presentation with IRS Appeals Officer and Examining Agent - State Bar of Texas 46th Annual Advanced Estate Planning and Probate

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Public Comment Letters on Direct Pay and Transferability Provisions Under the IRA-Notice 2022-50

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Public Comment Letters on the Prevailing Wage, Apprenticeship, Domestic Content, and Energy Community Requirements Under the IRA-Notice 2022-51

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Public Comment Letters on Clean Hydrogen and Clean Fuel Production Credits Under the IRA-Notice 2022-58

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Public Comment Letters on Carbon Capture Tax Credit Filed in Response to Proposed Regulations Under Section 45Q