Steven M. Armstrong, JD, LLM (Taxation)

Current Role

Steve is the Director of Transactional Tax Planning for Rehmann.

Service Areas

• Tax planning for limited liability company, partnership, corporate, and real estate transactions
• Mergers and acquisitions
• IRS audits and private letter rulings
• Executive and key employee retention and compensation
• Estate and Succession Planning
• Litigation support

Experience

Steve has extensive experience in developing creative and effective tax strategies to address various issues that confront a business owner over the life of an enterprise, from the initial planning of a startup (or purchase of a business), through and including the sale or the succession of the business. Steve provides knowledgeable advice in the areas of IRS negotiation and response to audit requests. Steve has presented numerous seminars on various tax structuring matters including presentations for the Institute of Continuing Legal Education (ICLE), Michigan Association of CPAs, American Institute of CPAs, and local bar associations.

Before joining Rehmann, Steve gained fourteen years of experience in law firms where he provided authoritative advice in tax, business, estate planning and litigation.

A Closer Look

• Steve is one of the first attorneys in the U.S. to obtain a favorable ruling authorizing a tax-free spin-off of a high-risk business involved in asbestos litigation from its low-risk business activities.
• Steve has assisted clients with the sale of a business using “personal goodwill” to assure a single level of tax on the sale of goodwill and assure capital gain treatment on proceeds allocated to personal goodwill.
• Steve was the primary tax advisor recently on a converted partnership ESOP which was selected as the business transaction of the year in Michigan.
• One of Steve’s recent audit successes involved the gift of business interests that were sold a short time following the gift. The IRS argued that the sales price alone is relevant. Steve prevailed using a theory that because of the buyer’s synergies the business had a value to him that far exceeded fair market value while the gift value was properly based upon a hypothetical buyer who would not pay a synergistic value.

Steve is also a frequent contributor to articles on individual and business tax planning and has been quoted in the Wall Street Journal and New York Times.