Achievements

Won Michigan Tax Tribunal case, reversing City of Detroit Corporation Counsel ruling. Detroit was ordered to refund over $100,000 plus interest in wrongfully assessed taxes. Reported case 1310-1314 Broadway LLC v City of Detroit, MTT 347864, February 4, 2011

Won IRS Appeals resulting in tax savings of $50,000 to taxpayer. Issue in dispute was determination of S-corporation basis created through related party transactions.

Prevailed in IRS Appeals Hearing, saving client more than $100,000 in Trust Fund Recovery Taxes and Penalties (for failure to pay employment taxes).

Guided medical device company in the application of AI to create new orthodontic treatment protocols.  Structure joint venture with technology development company.  Create licensing relationships and business models.

Analysis of laws of all 50 states concerning commercial co-ventures where a portion of retail sale proceeds go to charity.  Evaluate strategy for “going national” and develop program to comply with laws in each state.

Negotiated numerous executive compensation and employment agreements.  Developed equity and deferred compensation packages (including phantom stock, 409A, stock option, and restricted stock agreements).

Advised senior management on mergers, acquisition, sales, and divestitures, involving public and private corporations. Led legal due diligence evaluation of transactions. Analyzed state and federal regulatory and tax issues related to transactions. Negotiated and drafted definitive transaction documents.  Developed Shareholder and Operating Agreements allocating economic risks and benefits to parallel business risks and benefits.

Favorably resolved claims for overtime pay, vacation pay and unemployment compensation, in hearings before Michigan government and judicial panels.

Prepared and filed with IRS, first PLR Request to obtain partnership tax status for entity formed under new Michigan LLC law. IRS granted request on all issues.

Saved taxpayer more than $20,000 with analysis and development of 706-NA reporting position based on tax treaty with Switzerland. Client was a United States beneficiary of non-resident non-citizen (Swiss decedent).

Negotiated with PBGC and DoL to win amnesty for delinquent plan filed under PBGC Voluntary Disclosure Filing Program. Analysis of 401k Plan documents and implementation for compliance with ERISA and DoL Requirements.

Extensive experience working with technology companies addressing software licensing, social media legal issues, and incentive and stock option compensation.

Negotiated numerous leases and subleases for client with office locations in 6 states.  Structured leases to comport with business strategies including termination rights (with minimal penalties).

Collaborated with franchisor to create first-ever phantom equity allowing master franchisor to incentivize key employee and increase access to capital.

Restructured business ownership and management, to successfully guide business through WBENC certification process.

Contributing author of Advising Closely Held Business in Michigan, published by ICLE.