From 1977 to 1984, Frank Emmons worked as an attorney for the Chief Counsel’s office of the Internal Revenue Service. Since 1984, he has been in private practice. He is also a certified public accountant. In addition to the service areas outlined below, on a day-to-day basis, Frank advises clients on myriad income, payroll and excise tax issues including compliance and reporting issues (domestic and international), and qualification for advantageous tax treatment.
My work in this area involves the purchase and sale of businesses or divisions of businesses, which could take the form of asset purchases, stock purchases, joint ventures or tax-free mergers. This would include transactional and long-term tax planning and structuring, high level due diligence on tax issues, and drafting and reviewing the tax-oriented sections of transactional documents.
In this area, I work with clients on tax planning and the attendant structuring issues, including the drafting and review of the tax-oriented provisions of offering documents and governance documents.
A significant portion of my transactional and formation work has international aspects such as the acquisition by non-U.S. businesses of U.S. businesses or interests therein, or the converse.
I have significant experience in federal, state and local tax controversies, including dealings with the examining agents at the audit level, administrative appeals, numerous trial of cases in the United States Tax Court and other forums, and appeals to both federal and state appellate courts. I also have significant experience in such issues as income tax reporting issues (domestic and international), voluntary disclosures (domestic and international), private letter ruling requests and, in conjunction with other members of the firm, criminal tax investigations and controversies.
Fiscalità e Commercio Internazionale | October 01, 2016
Article by Charles Bernardini and Frank Emmons on sales tax and use tax issues facing foreign companies selling and installing manufacturing equipment in the United States.
Northwestern University School of Law, J.D., cum laude, Member, Editorial Board, Journal of Criminal Law and Criminology
Marquette University, B.S., magna cum laude
U.S. Court of Appeals, Seventh Circuit
U.S. District Court, Northern District of Illinois