The Holme Roberts & Owen LLP (HRO) tax practice includes more than 15 lawyers who dedicate the majority of their practice to federal income, state and local tax matters.

Our Practice

 

• Federal, state and local tax planning for new, emerging and established businesses.
• Federal and state income tax planning for mergers, acquisitions, dispositions and other business transactions
• Natural resource transactions planning and structure
• Federal, state and local dispute resolution at all levels, from audit to appellate courts
   

We provide counsel to corporations, trusts, partnerships, individuals, charitable organizations and other entities on local, domestic and multi-national levels. The tax group has in depth experience and knowledge and has advised clients in the banking and finance, commercial, real estate, technology, oil and gas, mining, telecommunications, and public utilities arenas.

Examples of how HRO has recently assisted clients include the following:

 

• Represented the shareholders of a domestic corporation in a $1+ billion stock-for-stock exchange with a major foreign company
• Represented borrowers in a $300 million revenue backed notes financing
• Represented a European communications company in a $1+ billion initial public stock offering on the Amsterdam and NASDAQ exchanges
• Represented domestic and foreign issuers in several discount note offerings in the U.S. and foreign markets ranging from $100 million to more than $1 billion
• Represented several technology-based companies in structuring and restructuring their European operations
• Represented a client in the formation of a European telecommunications joint venture that is constructing and operating fiber optic rings throughout Europe and offering connectivity between Europe, the United States, Mexico and Japan
• Represented an international packaging company in obtaining a treaty exemption for the sale of its international operations
• Represented a rapidly growing communications company in several like-kind exchanges involving telecommunications capacity
• Represented the purchasers with respect to the acquisition of a major sports franchise
• Represented the owner/operator in the acquisition, development and sale of a series of secondary recovery projects
• Secured numerous private letter rulings from the Internal Revenue Service relating to the availability of the Section 29 credit
   

Real Estate Investments

 

• Represented real estate developers and investors in acquisitions, dispositions and workouts
• Represented developers of affordable housing in equity financing based upon the low income housing tax credit
• Assisted numerous clients with the formation of partnerships, S corporations and limited liability companies for real estate transactions
   

Planning for Bankruptcies and Workouts

 

• Represented a business park developer in the workout of $25 million mortgage loan
• Represented debtors in debt restructuring transactions to preserve the carry-forward of tax losses
   

Litigation and Tax Controversy
 

• Secured several hundred million dollars in property tax valuation reductions for public utilities and owners of  properties ranging from luxury hotels to producing oil and gas properties.
• Negotiated a $33 million reduction in Colorado corporate income tax liability
• Obtained multi-million-dollar reductions in Montana and Wyoming mineral production tax assessments
• Secured a complete concession from the First Appellate Division of a multi-million-dollar payroll tax assessment.