Practice Strengths

Reportable Transactions

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 80 lawyers—many of whom have served as senior government tax advisors and have received substantial leadership recognition within the legal profession—Baker Hostetler'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.

Leadership in Action
Reportable Transactions/Tax Shelter Compliance
Monitorship under DOJ Agreement
Client: One of the world's largest financial institutions.
Type of Matter: Implementation of quality control procedures for certain types of transactions, often involving complex tax strategies, under an agreement with the Department of Justice.
Our Client's Challenge: Our client entered into an agreement with the Department of Justice concerning its participation in certain types of transactions, which often involve complex tax strategies. Pursuant to the agreement our client needed to put in place and follow a number of controls and procedures.
The Goal: To work with the client as a monitor on behalf of the DOJ to ensure compliance. 
Our Strategy: Working closely with the client, we reviewed its procedures and also designed workable internal protocols that will help ensure that the terms of the agreement are being followed.
Results: The client has agreed to institute the vast majority of the recommendations provided by Baker Hostetler over the course of the monitorship.


Leadership in Action
Reportable Transactions/Tax Shelter Compliance
Monitorship under DOJ Agreement
Client: One of the world's largest financial institutions.
Type of Matter: Implementation of quality control procedures for certain types of transactions, often involving complex tax strategies, under an agreement with the Department of Justice.
Our Client's Challenge: Our client entered into an agreement with the Department of Justice concerning its participation in certain types of transactions, which often involve complex tax strategies. Pursuant to the agreement our client needed to put in place and follow a number of controls and procedures.
The Goal: To work with the client as a monitor on behalf of the DOJ to ensure compliance. 
Our Strategy: Working closely with the client, we reviewed its procedures and also designed workable internal protocols that will help ensure that the terms of the agreement are being followed.
Results: The client has agreed to institute the vast majority of the recommendations provided by Baker Hostetler over the course of the monitorship.


Tax—Reportable Transactions Lawyers
Stuart J. Bassin Partner
Washington, DC 202.861.1736
Naomi Meisels Staff Attorney
New York 212.589.4217
Jeffrey H. Paravano Partner
Washington, DC 202.861.1770
David J. Strauss Partner
Cleveland 216.861.7472
Date Tax—Reportable Transactions Events
3/25/2009 VIDEO HIGHLIGHTS—20th Annual Tax and U.S. Legislative Policy Seminar
Date Tax—Reportable Transactions Articles
5/4/2009 Tax Notes Today: Managing Tax Accrual Workpapers After Textron
For more information about our Reportable Transactions practice, contact:
National Contacts
Paul M. Schmidt 202.861.1760
Chicago
Ronald S. Okada 312.416.6210
Cincinnati
David G. Holcombe 513.929.3402
Cleveland
Christopher J. Swift 216.861.7461
Columbus
Edward J. Bernert 614.462.2687
Costa Mesa
George Mooradian 714.966.8800
Denver
Raymond L. Sutton, Jr. 303.764.4103
Houston
Lisa Pennington 713.646.1303
Los Angeles
Neil Carrey 310.442.8835
New York
Elizabeth Ann Smith 212.589.4277
Orlando
James V. Etscorn 407.649.4067
Washington, DC
Paul M. Schmidt 202.861.1760

Contact

National Contact
Paul M. Schmidt
202.861.1760


Contacts by Office »

Representative Clients

Accounting/Investment Firms

Banks and Financial Services Institutions

Corporations

High Net Worth Families and Individuals

Practice Highlights

We are one of the largest tax groups of any law firm in the country, with more than 80 lawyers in 11 offices nationwide.

While at U.S. Treasury, one of our team leaders was a primary author of the final tax shelter regulations.

Our team co-authored BNA Tax Management Portfolio 798, Tax Shelters.

Our Washington practice represents the interests of clients during the legislative process as tax policy is made and tax law is written.