GMG has broad experience with the federal tax issues facing utilities. We have represented clients on numerous matters with the IRS, including audit and appeals issues, private letter rulings, and technical advice memoranda. In particular, GMG has extensive experience with the IRS National Office requesting permission to change methods of accounting and projects dealing with the re-characterization of capital/expense. Additionally, we have assisted utilities with numerous tax planning issues including the structuring of proposed transactions. Beyond structuring, we have advised clients regarding the maintenance and proper utilization of net operating losses.
We have also helped our utility clients on a myriad of state and local tax issues. These include the challenge of a state law as violative of the US Constitution's Commerce Clause, gain recognition disputes on sale of assets pursuant to deregulation, and audit defense.
At GMG, we understand the pressures of state and federal regulation. From seeking regulatory approvals to rate case support, GMG has the experience to lend support dealing with tax issues and their impact on the regulatory function. This includes flow-through/normalization decisions, rate base consulting and other issues concerning the proper impact of taxes in the setting of rates.
GMG has a keen understanding of the expenses incurred and assets present in a utility. This knowledge, combined with our overall knowledge of sales and use tax allows us to best provide help on an issue-by-issue basis, on audits, and in reverse sales and use tax refunds.
We regularly provide
clients with technical assistance in all areas of state
and local tax and are available to answer day-to-day