Tax Compliance and Tax Controversy

McCall represents clients in all aspects of continuing compliance, including federal tax dispute resolution with the IRS. We have extensive experience in helping issuers implement effective compliance policies and procedures, in responding to questionnaires and in defending audits which challenge the tax-exempt status of debt obligations. We handle audits, voluntary closing agreements and administrative appeals. The firm also assists clients in complying with the federal tax restrictions on dispositions of bond-financed property and other changes of use of such property. McCall neither represents clients in civil or criminal tax cases in federal or state courts nor performs tax accounting or financial advisory services, although it is available to assist clients in connection with the handling of such cases or the obtaining of such services.

The Tax-Exempt Bond office at the Internal Revenue Service (IRS) has developed formal and informal programs which seek to determine the level of continuing compliance with the federal tax laws. As part of their programs, the IRS has adopted many new methods of information gathering, including the distribution of questionnaires which monitor internal compliance policies, procedures and recordkeeping. These programs, in turn, have resulted in significant increases in the number of formal audits of bond issues by the IRS.

Issuers and purchasers of tax-exempt securities, without regard to their level of sophistication, must face the ever-changing challenges presented by the federal tax laws. Tax lawyers at McCall help clients meet those challenges. Beginning with the enactment of the first substantive tax statutes relating to tax-exempt securities, the firm’s tax lawyers have specialized in analyzing and planning unique and complex financial transactions and in representing clients before the U.S. Department of Treasury and the tax-writing committees of the U.S. Congress. Lawyers in our tax department have reputations for the highest level of competency and ethical responsibility as established by independent national rating services.

Tax Planning

The firm’s tax lawyers work closely with the other attorneys in the firm in reviewing public finance transactions by monitoring compliance with federal tax laws. Their extensive expertise permits them to render tax opinions that reconcile a high standard of prudence with an ability to use innovative financing techniques. Their unique experience as practitioners with the federal government and multinational accounting firms permits them to complement their analysis of legal authorities with a sensitivity to federal tax policy and IRS enforcement procedures. In addition to assisting attorneys at the firm, the tax department has assisted numerous other public finance law firms as special tax counsel.

Tax Controversy

Uncertainty in today’s legal environment and the complexity of the modern financial market demands an understanding of the role that the IRS plays in monitoring the tax-exempt securities market and enforcing federal tax rules. McCall’s tax lawyers have a widely-recognized history of representing clients before the IRS and an established depth of experience in dealing with tax controversy matters relating to public finance. Our attorneys have represented clients relating to numerous IRS audits and inquiries. Because of our sensitivity to the ethical challenges and disclosure obligations presented in these circumstances, our tax lawyers act with the greatest discretion and professionalism in assuring that the interests of the client are paramount in the outcome of the proceedings.

IRS Building