Something Different: An Income Tax “Potpourri” Webinar
On December 10, 2020, speakers from Fredrikson & Byron and RSM discussed a collection of interesting, diverse, and thought-provoking tax issues and events from 2020.
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Our tax controversy attorneys come from a variety of backgrounds, including experience as government counsel, public accounting, and tax court clerkships.
Read Masha Yevzelman’s Tax Notes State article “Minnesota Data Center Exemption: DOR’s Revised Guidance Shows Progress”
Our team of skilled attorneys provides experienced, effective representation in preparation for and throughout the tax controversy process. We offer full‑service representation on a multistate basis, and at all stages of the tax controversy process:
Frequently, our early involvement at the examination or protest stages permits us to help the taxpayer marshal the critical underlying facts and to define the arguments most likely to prevail. In addition, we bring the benefits of attorney‑client confidentiality and privilege to the controversy.
When litigation is advisable or necessary, we draw upon our trial experience to choose the appropriate court, develop the case through formal and informal discovery, and aggressively advocate the taxpayer’s position before the judge or jury. Our tax litigators have extensive experience in federal district courts, the United States Tax Court, the Minnesota Tax Court, the Wisconsin Tax Appeals Commission, State District Courts, the Eighth Circuit Court of Appeals, the Minnesota Supreme Court, the North Dakota Supreme Court, and the Minnesota Court of Appeals. We know tax law, but more importantly, we have the experienced advocate’s ability to develop and present the most persuasive arguments and themes.
Throughout our representation, we strive to obtain fair and thoughtful review of the dispute to achieve the best possible result for our client at the earliest opportunity.
We represent publicly owned and privately held corporations, partnerships, cooperatives, individuals and fiduciaries in tax disputes and litigation of all types against State and Federal taxing authorities. Our clients are well-recognized national, regional and local businesses. We regularly negotiate and litigate tax disputes involving corporate and personal income taxes, sales and use taxes, excise taxes, estate and gift taxes, employment taxes, property taxes, and healthcare provider taxes.
Federal Tax
Sales/Use Tax
Minnesota Corporate Income Tax
Minnesota Individual Income Tax
Property Tax
November 23, 2020
On December 10, 2020, speakers from Fredrikson & Byron and RSM discussed a collection of interesting, diverse, and thought-provoking tax issues and events from 2020.
November 17, 2020
The Minnesota Department of Revenue has updated its data center exemption guidance, taking a step in the right direction for purchases of distributed software and required documentation.
November 10, 2020
By Emily M. Chad and John J. Erhart
As of November 9, 2020, owners of partnerships and S corporations in those states allowing pass-through entities to pay state tax at the entity level can deduct those taxes on their federal returns with the U.S. Department of the Treasury’s blessing.
November 3, 2020
On November 12, 2020, members of our Tax Litigation Group addressed the top ten myths about changing your Minnesota residency, including myths such as: there is an all-inclusive binding checklist for changing residency, you can’t keep any MN contacts after you leave, and there is a medical exception to residency.
September 15, 2020
This session explores the considerations sellers should be aware of and discuss some strategies to consider when looking to mitigate state tax risks associated with such discussions.
July 27, 2020
This session evaluates how we got to the current state and focuses on challenges that taxpayers face when evaluating whether they have state tax nexus.
May 19, 2020
By Kyle M. Brehm and David B. Tibbals
With the COVID-19 pandemic continuing to impact businesses within the healthcare industry, the Minnesota Department of Revenue on May 14, 2020, again offered relief to businesses with upcoming MinnesotaCare tax payment obligations.
May 7, 2020
Corporate tax departments are continually being asked to provide more documentation to defend assessments on transactions which are clearly not taxable or oftentimes have already been subject to tax. This session focuses on discussing these issues and preparing for the fight before it shows up at your door.
April 30, 2020
State tax controversy can present daunting strategy issues for taxpayers as well as service providers. This session focuses on preparing for controversy prior to audit division involvement and discusses potential strategies for defending a taxpayer position throughout the agency review phases (both audit and appeal).
April 23, 2020
This webinar provides participants with the knowledge they need to evaluate whether a property tax appeal makes sense for their properties.
April 22, 2020
By Masha M. Yevzelman and David B. Tibbals
As social distancing methods and shelter-in-place orders during the COVID-19 pandemic have prompted many across the country to work from home, businesses have begun to wonder about the nexus ramifications of their newly-expanded telecommuting arrangements.
April 16, 2020
Our panelists address taxpayer questions their offices are most frequently asked to respond to as a result of the current environment we are working within.
April 13, 2020
By Kyle M. Brehm and David B. Tibbals
With the COVID-19 pandemic continuing to disrupt business operations, the Minnesota Department of Revenue on April 10, 2020, offered additional relief to those businesses with upcoming MinnesotaCare tax payment obligations.
April 10, 2020
By Kyle M. Brehm and David B. Tibbals
On April 9, 2020, in its latest response to the COVID-19 pandemic, the Minnesota Department of Revenue offered expanded relief for businesses impacted by Emergency Executive Order 20-04. The expanded relief measures extend the payment deadline associated with these returns to May 20, 2020.
April 2, 2020
In light of the COVID-19 crisis, restaurants and businesses have shut down their operations. Tenants are struggling to pay their rent and landlords are left bearing the burden of vacancies and non-payment. Many property owners anticipate this will lead to a decrease in property values, and have already begun asking the question: Should I appeal my property taxes?
March 30, 2020
The CARES Act, signed into law on March 27, 2020, makes important changes to certain key tax provisions for businesses affected by COVID-19.
March 26, 2020
By David B. Tibbals and Michael S. Raum
The IRS announced on March 24 that it has indefinitely suspended nearly all functions and services requiring face-to-face contact with taxpayers.
March 23, 2020
The Minnesota Department of Revenue, recognizing that several of the businesses subject to MinnesotaCare Tax have been impacted by the COVID-19 pandemic, announced certain relief measures for businesses who were unable to properly file returns by March 16, 2020.
March 21, 2020
By Kenneth S. Levinson, Masha M. Yevzelman, David B. Tibbals and Karen Sandler Steinert
COVID-19 has had innumerable impacts on our daily lives. In response, the IRS and certain local states have provided guidance for taxpayers whose federal income tax returns are due on April 15.
March 19, 2020
By Kyle M. Brehm and David B. Tibbals
Responding to the COVID-19 pandemic, Minnesota Governor Tim Walz issued Emergency Executive Order 20-04 on March 16, 2020.
September 10, 2018
Individuals or companies with undisclosed foreign financial assets or income have until September 28, 2018 to enter the IRS’s Offshore Voluntary Disclosure Program.
June 22, 2018
By Masha M. Yevzelman & Thomas R. Muck
A merchant of goods and services that makes sales in multiple states is no longer required to have physical presence in a state in order to be subject to sales and use tax in that state.
February 6, 2018
In 2015, Congress passed 26 U.S.C. Section 7345, entitled “Revocation or Denial of Passport in Case of Certain Tax Delinquencies.” Although this law was passed in 2015, the IRS did not begin coordinating with the State Department immediately. However, it has announced that it will begin that process in January 2018.
May 31, 2017
By Masha M. Yevzelman & Thomas R. Muck
When evaluating whether an individual is a Minnesota resident, the Minnesota Department of Revenue has been considering, among many factors, the location of a person’s attorney, accountant, financial adviser and bank accounts.
January 18, 2017
By Wayne W. Carlson, Michael S. Raum & Elizabeth L. Alvine
No one wants to be audited, whether by the IRS or the state tax authorities. However, there may be instances in which it is important to make sure that you are actually subject to an audit, in order to ensure that your rights are protected.