Christie R. Galinski

• IRS Penalty Abatement: Successfully obtaining removal of IRS penalties and responding to IRS letters. Effectively navigating IRS audits, penalty abatements, closing agreements and private letter rulings.

• Tax Planning for Small and Large Businesses: Helping companies of all sizes with tax planning at every stage, from founding to dissolution. Advising on tax issues like selecting entity types, maintaining the preferred entity type, and tax efficient structuring of operations and transactions.

• Tax Planning for Partnerships, C-Corporations and S-Corporations: Tax planning for partner and shareholder contributions and distributions, as well as asset sales, stock sales and restructuring. Issues include equity compensation options for partners and qualified small business stock exclusions for corporate stock under Section 1202.

• Tax-Exempt Entities: Assisting tax-exempt entities in obtaining and maintaining their tax-exempt status and qualifying for grants and other financing, including tax due diligence and tax opinion letters.

• International Tax Issues and U.S. Tax Treaties: Advising on U.S. tax law and tax treaties for cross-border lending, sales, other inbound and outbound transactions, including withholding taxes and FATCA compliance.

• M&A: Advising on planning asset sales vs stock sales, performing tax due diligence and reviewing sale and purchase agreements, including hospitals, other 501(c)(3) organizations, banks and international companies.

• Litigation Matters: Assisting litigators on lawsuits that involve tax claims. Also, advising plaintiffs and defendants on tax treatment of settlements for lawsuits that may or may not involve tax matters.

• Tax Incentives: Advising and writing tax opinions regarding federal tax incentives, including low-income housing, Investment Tax Credits and other energy tax credits.

• State Taxes: Identifying employment and income tax risks for employees working remotely out of state or out-of-state workers commuting to work in the employer’s state.

• Financial Products: Providing tax advice and assisting with legal documentation for Real Estate Investment Trusts, Regulated Investment Companies, credit agreements, and private placements.

• Payroll Taxes: Advising employers on compliance with withholding for federal income tax, employment taxes and state income tax, including for international employees.

Panelist, "Tax and Employee Benefits Talk: Frequent Tax Issues Facing HR & Updates on SECURE 2.0," Miller Canfield 2024 HR Spring Training