Supreme Court Agrees with IRS that 40% Penalty Applies to Partners’ Tax Understatements
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James T. Chudy
Pillsbury's tax practice brings a full-service, interdisciplinary approach to the resolution of diverse tax-related issues. We serve as trusted advisors to a broad client base in a wide range of domestic, international, state and local tax matters. We assist in all aspects of tax planning to enhance the tax efficiency of our clients’ activities and transactions, to limit their exposure to controversy, and to help them comply with applicable federal, state and local tax laws wherever they might do business. When disputes with the Internal Revenue Service or state taxing authorities do arise, we are well equipped to handle all stages of tax controversy matters at both the administrative and judicial levels.
Our clients are multinational corporations, financial institutions, international and domestic joint ventures and project developments, new business ventures, nonprofit organizations and individuals. They include companies in traditional businesses such as energy, utilities, aerospace, pharmaceuticals, transportation, packaging, distribution, newspapers and publishing, technology businesses such as telecommunications, Internet providers, hardware manufacturers and software developers, real estate owners and developers, professional sports franchises and biotechnology firms.
With experience in the United States Department of Justice’s Tax Division, in the Internal Revenue Service’s (IRS) Office of Chief Counsel, in the California Department of Justice, in the State of California Franchise Tax Board and State Board of Equalization, on Capitol Hill, in national accounting firms and in industry, Pillsbury's tax lawyers have worked with and understand our nation’s federal, state, and local tax laws and tax systems from all angles.