Transactions Have Business and Tax Consequences

The federal tax code is constantly changing.  In such a dynamic environment, properly structuring the business dealings of entities and individuals to take into account the complex tax rules is vital .  Drawing on years of experience, Kevin Bagley takes great care to answer the questions and explain the intricate issues his clients face in terms they can understand.  His goal is to assist his clients in creating comprehensive solutions that address their distinct business and tax requirements.

Kevin’s practice also includes succession planning for his high net worth business clients to maximize wealth transfers and minimize estate and gift taxes.

Business Formations, Combinations, Liquidations

No business entity is right for all situations, but choosing a limited liability company, general partnership, limited partnership, “C” Corporation, “S” Corporation or business trust without a clear explanation of the differences can haunt a business for years.  Which business entity is right for your enterprise?

Kevin’s clients are engaged in diverse industries and he has negotiated all aspects of formation, finance, reorganization, stock and asset purchases and sales, redemptions and liquidations with an eye on deal points and tax consequences.

Partnerships and Limited Liability Companies

When faced with incomprehensible “allocation provisions” in a partnership or limited liability company Operating Agreement, you might throw up your hands and move on, saying to yourself, “It’s just tax stuff”  It’s not just tax stuff.  Unforeseen consequences can arise from the too common practice of attorneys blithely incorporating complex provisions of the §704(b) “tax” regulations from one partnership or LLC agreement to another.  The economic consequence of the deal is the underlying premise of the regulations where the general rule is “tax follows book.”

Are you involved in a partnership or LLC dispute?  Tax returns contain a wealth of information often ignored in both negotiations and litigation.  Even if unrelated to the particular dispute, drilling down into agreement’s income allocation and cash distribution language with the tax returns at hand can reveal reporting discrepancies to give you an edge.

Tax Disputes

Kevin has represented businesses, estates and individuals at all levels of tax disputes with local, state and federal authorities, from the first contact with the government through litigation.  His knowledge of the inner workings of the IRS and experience with representatives of other tax authorities gives him the ability to find the “right” person inside the government with a minimum of time and expense.