Policy’s Essential Role in a Pro-Active Tax Strategy

Businesses and their internal tax advisors are keenly aware of the value of a thoughtful tax strategy to their success.   Aggressive competition, global-growth demands, and mounting economic uncertainty require making the most of every available resource.   Pro-active tax strategies can play a key role in minimizing today’s challenges and maximizing tomorrow’s opportunities.

Tax policy is an indispensable element of an integrated tax strategy.  A powerful complement to comprehensive tax management, tax policy informs the range of an enterprise’s strategic needs, from tax planning, to resolving tax controversies, to pro-active change through legislation or regulations.   In the growing intricacy of the Internal Revenue Code, companies are finding fewer shared issues and more –- and tougher -- challenges specific to each.  In this highly-charged environment, a multi-faceted tax strategy that maximizes the abundant potential of tax policy is an essential business tool.

A Formidable Mix of Talent in Tax and Tax Policy

Our Tax Policy practice is fully integrated with our internationally-ranked Tax practice. Consistently rated among the top echelon of tax law counsel, Miller & Chevalier has been helping our clients achieve their business objectives in Congress, the Treasury Department, and the Internal Revenue Service since our founding as the first federal tax practice in the United States.  During that time, our lawyers have participated in the development and implementation of every significant piece of federal tax legislation, winning the respect of legislators for our integrity, technical expertise, and policy acumen.   Our formidable combination of government experience and tax expertise, in particular, distinguishes our practice and offers a distinct advantage to our clients.

Our clients include the world’s largest multinational corporations, U.S.- and foreign-based, as well as trade associations, industry coalitions, foreign governments, and tax-exempt organizations.  They are sophisticated and discerning entities who value our proven leadership in tax policy and our record of achievement on behalf of our clients.  They rely on us to resolve their toughest issues, to anticipate the potential challenges and business opportunities associated with legislative or regulatory change, and to influence changes in policy that affect their interests.   We represent them across many industries, including manufacturing, energy, agriculture, high-technology, consumer products, financial services, and pharmaceuticals.

We represent our clients’ interests before Congress, the Treasury Department and the IRS, as laws are enacted and as guidance is developed to implement those laws.   We help clients achieve sound and practical business solutions in highly technical matters as well as with major policy issues that have national and international implications.   Our thorough understanding of the workings and decision-making processes of Congress, the Treasury Department and the IRS enable us to match our clients’ interests and needs with opportunities that are precisely suited to their objectives.

The Advantage of Legislative and Regulatory Know-How

Creating and implementing strategies to enact, modify or oppose tax legislation is a major part of our practice.   We analyze legislation on behalf of our clients and alert them to risks and opportunities.   We assist them in crafting strategies to present their positions effectively to decision-makers, and we prepare crucial materials to promote and support those strategies.  These include position papers, testimony for Congressional hearings, proposed statutory language, and proposed legislative history and revenue estimate requests.

Once legislation has been enacted, we represent our clients’ interests before the Treasury Department and the IRS as they develop regulations and other administrative guidance.  We provide suggested guidance to Treasury and IRS officials, as well as written comments and public testimony.

Our long-standing relationships with the Congressional tax-writing committees, the Treasury Department and the IRS add to our ability to represent clients effectively and to achieve favorable solutions to their issues.  We reinforce this with the experience of the many Miller & Chevalier lawyers who have held senior tax policy-making positions in the Government, among them:

• Majority Tax Counsel, Committee on Ways and Means , U.S. House of Representatives
• Assistant Chief of Staff, Joint Committee on Taxation
• Commissioner, Internal Revenue Service
• Assistant Commissioner (Technical), Internal Revenue Service
• Assistant to the Commissioner, Internal Revenue Service
• Deputy Chief Counsel (Operations), Internal Revenue Service
• Deputy Associate Chief Counsel, (Litigation), Internal Revenue Service
• Associate Chief Counsel (Income Tax and Accounting), Internal Revenue Service
• Special Assistant for Fringe Benefits, Associate Chief Counsel, Internal Revenue Service
• Tax Legislative Counsel, U.S. Department of the Treasury
• Deputy Tax Legislative Counsel, U.S. Department of the Treasury
• Associate International Tax Counsel, U.S. Department of the Treasury

A Leading Role in Tax Policy Research

Miller & Chevalier is at the forefront of tax policy issues.  Each year, as part of our ongoing effort to better understand client concerns and explore industry issues, we commission al tax policy survey.  Our current study -- the 2008 Tax Policy Forecast Survey -- measured the perspective and attitudes of leading corporate executives on the direction of tax policy.   Please click on the link above for a full copy of the results and analysis of the survey.

Click here to read more about our Tax Practice.