Rob Munnelly and Richard Hindlian

Our tax practice focuses on:

  • selecting an appropriate jurisdiction and business entity choice designed to minimize tax obligations
  • providing tax-efficient designs for commercial transactions
  • planning for international transactions and using business structures based in Europe, Asia and offshore locations
  • providing reasoned tax opinions 
  • assisting businesses in completing tax registrations and making appropriate tax elections
  • assessing impacts on employee benefit plans, “golden parachutes” and deferred compensation in matters involving business reorganizations, acquisitions, spinoffs and other contexts
  • offering tax-efficient succession planning and exit strategies for maturing businesses
  • minimizing tax burdens and resolving controversies, including tax liens and levies, with taxing authorities
Results

Our strong track record of success.

  • Provided tax counsel and prepared tax opinions regarding the impact of federal, state and local taxes (including income, excise, sales and real estate transfer taxes) for acquisitions of national companies in several jurisdictions.
  • Advised a U.S. software firm opening a South American sales office and determined appropriate methods for tax reduction on repatriated profits returned to the U.S. company.
  • Developed a specialized partnership income allocation structure for real estate investments to maximize depreciation and allocate tax losses to the higher-income partners.
  • Represented a split-interest trust in complex income tax IRS litigation in the U.S. Tax Court, coupled with related-party ongoing income tax audits related to multiple tax years in the Appeals Office.
  • Concluded a complex §1031 like-kind real estate exchange transaction for a grantor trust with multiple beneficiaries resident in many states.
  • Resolved an IRS penalty case for 8,000 late-filed 1099 forms issued to medical service providers by three tax-exempt medical plan insurers with respect to over 100 plan clients.
  • Resolved and issued an opinion regarding the tax treatment of a settlement payment made to heirs of a decedent where the will was allowed.
  • Advised the trustee of a charitable remainder trust regarding amendment of the trust agreement in compliance with the Federal Tax Law.

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Publications

January 31, 2024

Massachusetts Taxation and DOR Practice Guide

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Publications

January 31, 2024

Adult-Use Cannabis Licensing (MA)

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Speaking Engagements

January 18, 2024

Business Immigration Fundamentals

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Firm Announcements

December 19, 2023

Davis Malm Attorneys Serve as Contributing Authors for ILN’s 2023 Edition of “Establishing a Business Entity: An International Guide”

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Speaking Engagements

December 11, 2023

2023 Massachusetts State Tax Update

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Alerts

December 5, 2023

Be Prepared as the Corporate Transparency Act (CTA) Takes Effect January 1, 2024

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Alerts

November 29, 2023

Highlights of the New Massachusetts Rules Implementing the Cannabis Act

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Publications

November 1, 2023

Massachusetts State and Local Tax Update – Third Quarter 2023

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Speaking Engagements

October 26, 2023

Forming a Company

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