Practice Strengths

Our Reportable Transactions Services team takes a proactive and practical approach to dealing with the complex web of regulations that require disclosure of tax shelters-or potentially abusive tax avoidance transactions. The current disclosure rules, while more coherent than earlier versions, still require careful analysis and interpretation, particularly in view of significant new penalties for failure to comply.

Our team has designed and implemented systems that help clients ensure compliance with the reportable transaction disclosure rules on a cost-effective basis. We offer an alternative to expensive, off-the-shelf compliance “packages” sold by other service providers. Our extensive experience lets us target situations and issues where there are significant disclosure risks.

We provide independent, timely and cost-effective reviews of both proposed and executed transactions to determine whether disclosure is required. We work together with clients to find an overall solution for a potentially reportable transaction—one that takes into account their existing corporate risk minimization policies. We provide responsible advice that takes into account penalty protection and privilege alternatives.

In fact, you might say that we “wrote the book” on reportable transactions. Members of our team co-authored BNA Tax Management Portfolio 798, Tax Shelters and often participate in cutting-edge forums on tax shelter policy. One of our team members was a primary author of the final tax shelter regulations.

About Our Tax Team

With a team of more than 75 lawyers—many of whom have served as senior government tax advisors and have received substantial leadership recognition within the legal profession—BakerHostetler's national tax practice offers unsurpassed resources to our clients. We can handle any tax planning matter or tax controversy at the state, federal or international level, and have the insight and experience to make the Tax Code work to our clients' advantage.