Schiff Hardin has a long history of representing businesses, organizations and individuals in state and local tax disputes. Our team is devoted to helping taxpayers successfully obtain tax refunds and defend against state and local tax deficiency assessments from the audit stage through administrative appeals and litigation. We have grown from a local Michigan-based practice to a regional and national practice.

Our tax litigators utilize their understanding of important, and sometimes little known, nuances within complicated tax acts to achieve favorable resolutions for taxpayers. We use that experience when helping a wide array of clients, including Fortune 100/500/1000 multi-state/multi-national companies, mid-sized businesses, closely-held businesses, non-profit organizations, families, and high net worth individuals. Our tax attorneys have represented utilities, independent power producers, national shopping centers, major industrial manufacturers, hotel chains, restaurants, office complexes, condominium and residential developments, and other commercial enterprises. 

  • Experience

    We have represented clients on a variety of issues relating to a wide array of state and local taxes, including:

    • Business/Corporate Taxes, including Michigan Corporate Tax, and the repealed Michigan Business Tax and Single Business Tax
    • Sales, use and withholding taxes
    • Franchise tax
    • Gross receipts tax
    • Severance tax
    • Motor fuel tax
    • Tobacco tax
    • Unemployment and payroll taxes
    • Municipal income taxes
    • Personal income tax
    • Real and personal property taxes
    • Special assessments
    • Utility taxes
    • Hotel and accommodation taxes
    • Municipal water and utility fees
    • Property tax credits and incentives
    • Unclaimed property tax audits and litigation
    • Tax legislation interpretation and drafting
    • Merger and acquisition structuring
    • Tax implications related to the sale or purchase of property
    • Officer liability
    • Successor liability
    • Class actions
    • Tax issues unique to charitable, educational, and religious non-profit organizations

    Seasoned Litigators and Advocates
    In any tax dispute, it is crucial that taxpayers choose the best course of action for their disputes, including whether to begin with an administrative appeal and, when litigating, whether to litigate in civil courts or in administrative tax tribunals. Our clients find our intimate knowledge of substantive tax and procedural laws and rules, firm commitment to staying abreast of substantive and procedural changes, and wide experience in advocating for clients in all venues, invaluable when making the critical choice of forum.

    Appellate Work
    We represent taxpayers in appeals before state appellate courts, federal courts and the U.S. Supreme Court. Our clients find our in-depth knowledge of both substantive tax issues and appellate court rules and procedures indispensable assets on appeal. While our appellate work is usually a continuation of our representation at the trial level, we are frequently brought in at the appellate level. Our tax attorneys, many of whom are former appellate clerks, are also experienced in writing amicus curiae briefs for businesses and trade organizations.

    From experience, our attorneys have developed a keen eye for appellate strategy. For example, tax-case presentations before appellate judges who hear a variety of cases can sometimes be won by simplifying a complicated tax issue, highlighting a procedural defect, or providing a legal “deep dive” on an ambiguous nuance within a tax act. Deciding which appellate strategy to take can be crucial to the outcome, and our team has had great success in mapping out winning strategies.

    Planning and Audit Assistance
    Our team provides a full range of tax planning services to clients. Sometimes this involves re-thinking the way transactions are structured or re-examining the tax advantages of a particular entity choice. We provide clients personalized advice in particular transactions and update them with recent changes in tax administration and audit practices that will affect their business. Working with other Schiff Hardin professionals to develop comprehensive, full-service solutions, we assist clients in preparing for and managing audits and resolving controversies before they rise to the next level.

    We regularly work with public accounting firms and corporate tax staffs, providing them legal advice on everything from tax sharing agreements, FIN 48, confidentiality protection for legal opinions in constitutional and substantive tax matters, and everything in between.

    Our tax attorneys are in the forefront on cutting-edge national SALT issues, speaking on the subject nationally and regularly publishing and teaching on matters relating to it. Because tax laws constantly change, we update our clients and professional partners in interpreting the impact of these changes. In addition, we offer targeted, in-house training, seminars and workshops, often for CPE credits, to corporate tax staffs and accounting professionals.

    Leadership and Accolades
    Our attorneys are regularly ranked among the top tax attorneys and tax litigators by organizations such as Super Lawyers, Best Lawyers in America, Leading Lawyers and the College of Tax Counsel.

  • Awards & Honors

    • U.S. News – Best Lawyers® “Best Law Firms” – Metropolitan Tier 1
      • Litigation – Real Estate, San Francisco (2015- 2021)
      • Litigation – Real Estate, Chicago (2012-2013)
      • Litigation – Tax, Ann Arbor (2016-2021)