REGULATORY & ADMINISTRATIVE LAW

Tax

Our tax attorneys take the time to understand your unique needs and goals, so they can help you find the most tax-efficient, cost-effective ways to accomplish them.  We distill the complexities of the tax laws down to clear choices, so you can make the best decisions for you, your business and your family.

Our clients include for-profit businesses and tax-exempt organizations of all sizes, from exchange-traded companies to early-stage enterprises. We serve local Boston businesses and worldwide conglomerates.

We zealously represent clients in controversies with the Internal Revenue Service and other tax authorities at all levels, from routine audits to complex litigation in the U.S. Tax Court and federal courts. Where appropriate, we seek IRS private letter rulings on important tax issues and other forms of administrative relief.

REGULATORY & ADMINISTRATIVE LAW PRACTICE AREAS

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 a wide variety of 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.

REGULATORY & ADMINISTRATIVE LAW ATTORNEYS

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Phil Olsen

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Philip S. Olsen

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Alerts

January 20, 2026

National Data Privacy Day: 8 Tips for Employers to Protect Company and Employee Data

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Firm Announcements

January 9, 2026

Robert J. Munnelly, Jr. Re-elected to NECA Board of Directors for Eleventh Consecutive Year

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Publications

December 17, 2025

Robert J. Munnelly, Jr. Contributes to LexisNexis Practice Guide: Massachusetts Administrative Law and Practice

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Speaking Engagements

September 16, 2025

Robert J. Munnelly Jr. Presents at the NECA Retail Markets Conference

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Publications

August 4, 2025

The Next Phase of Massachusetts’ Solar Revolution

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Publications

June 22, 2025

Evolving in a Time of Change: Next Steps for Massachusetts “SMART”

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Publications

June 20, 2025

Phil Olsen Serves as Contributing Author for 2023-2024 ABA Sales & Use Tax Deskbook

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Firm Announcements

June 12, 2025

Courtney A. Simmons Named a “Rising Star” by New England Real Estate Journal

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Publications

February 7, 2025

Attorneys eager to see how Trump crypto revolution takes shape

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