Planning & Structuring

Parsons Behle & Latimer's attorneys counsel a variety of businesses and employers in the design, implementation, and administration of tax-efficient arrangements that serve to attract, motivate and retain executive employees as well as promote alignment between these employees and business owners. We assist employers to comply with applicable laws and market standards, including the nuances of Section 83(b) elections and the use of profits interests and deferred compensation structures. Our corporate team has expertise drafting all types of executive employment, separation and consulting agreements, equity plans, and bonus and incentive plans.

Parsons Behle & Latimer's tax attorneys routinely handle complex income tax planning and controversy matters for business entities (limited liability companies, partnerships and corporations), and associated restructuring and reorganizations. 

Parsons Behle & Latimer's attorneys advise donor taxpayers in order to maximize the benefits they can confer on charities while providing tax-efficient strategies and vehicles for their own, and their children’s philanthropy. We advise on charitable remainder trusts; charitable lead trusts; conservation easement; charitable annuities; pooled income funds; donor advised funds; and private foundations. We advise charities and exempt organizations on obtaining 501(c)(3) and other determinations. Additionally, we help our clients to understand the difference between public charities and private foundations and how to comply and excise taxes relating to private foundations including those on self-dealing; excess business holdings; prohibited transactions; failure to distribute; and prohibited expenditures. We advise on special issues related to grants and scholarships. Also, we assist with qualification for state and local charitable exemptions and compliance with state Charitable Solicitation Acts.

Parsons Behle & Latimer's tax attorneys advise clients on state and local tax matters in the Western United States (primarily, Idaho, Montana, Nevada, Utah and Wyoming), on sales and property tax matters arising from operations and activity in these states. We support clients with both planning and representation before various state and local tax commissions.  

Parsons Behle & Latimer's tax attorneys specialize in counseling business on how to form and maximize the benefits of partnership and joint venture structures to appropriately allocate risk and profit. We have organized some of the largest mining partnerships and joint-venture structures.

Parsons Behle & Latimer specializes in taxation in United States possessions and the now freely-associated states formerly comprising the United States Trust Territory of the Pacific Islands. For possessions, there are federal income taxes; possession income taxes; and coordination provisions. For the “mirror image” taxes, which are actually federal levies, we advise clients on the Guam Territorial Income Tax; the Northern Mariana Islands Territorial Income Tax; and the United States Virgin Islands Territorial Income Tax. In other cases, such as the Samoan Income Tax levied by American Samoa; the taxes of the Federated State of Micronesia, Republic of the Marshall Islands, and Republic of Palau (Belau), we advise on United States law and coordinate with local counsel on local law. We advise on special provisions of United States estate, gift and generation-skipping transfer tax laws applicable to individuals acquiring U.S. citizenship from birth or residence in the possessions, applicability of employment taxes (FICA, Social Security, Medicare, FUTA, unemployment) and special excise taxes. We also advise on tax incentives offered by several of the possessions.