State & Federal

Tax Law

State and Federal Tax Law

Carney Badley Spellman is listed in Best Law Firms for Tax Law in the United States and Tax Litigation and Controversy and Tax Law in Seattle, Washington.

Washington State is unique in the field of state and local taxes; this state has no personal or corporate income tax, but it imposes one of the broadest based and highest rates of sales and use taxes in the country. Washington State is the home of one of the last and most all-encompassing gross receipts (known as the Business and Occupation or B&O) tax imposed by both the state and many city governments.

We have extensive experience working with clients to address federal, state, local and international tax issues associated with each client-specific transaction. Our attorneys represent financial institutions, corporations, partnerships, limited liability companies, and individuals. We have experience representing clients with issues related to federal, state and local tax audits, appeals and litigation. All of our attorneys have appeared before the Internal Revenue Service and the Washington State Department of Revenue.

In addition to assisting clients with the state and local tax implications of transactions, we also represent a diverse group of clients with state and local tax-related issues in a wide variety of industries, including forest products, utilities, manufacturing and refining, retail, wholesale trade and transportation. Our attorneys represent clients before administrative agencies, including the Washington Department of Revenue, county boards of equalization, State Board of Tax Appeals, and all levels of the Washington state courts.

Tax News:  US Supreme Court Gives States Expansive Authority to Collect Sales Taxes.

by George Mastrodonato

On June 21, 2018, the United States Supreme Court issued its long-awaited decision in South Dakota v. Wayfair. In this case the Court ruled that South Dakota (and, by implication, all states) can make out-of-state retailers collect sales taxes on internet or other sales of goods and services into the destination state, even where the seller does not have “nexus” or a “physical presence” in the state.   Full Article 

State and Local Tax

We have an experienced and respected group of state and local tax (SALT) attorneys to assist clients who transact or do business in Washington State. With our many years of combined experience, we can assist with virtually any issue in the specialized field of state and local tax law. Our full range of services includes:

  • tax advice and planning
  • assistance with audits
  • refund claims
  • purchase and sale transactions
  • protests of assessments
  • appeals before government agencies, boards and the courts

We handle all types of taxes: sales, use, gross receipts, utility, special excise and property taxes. Our clients include individuals, large and small businesses, multi-state entities and municipal corporations. We assist both individuals and businesses with yacht and aircraft transactions. Our client list includes wholesale, retail, power generation, professional services, manufacturing and refining and transportation. We have appeared before every major board and court in Washington that hears and decides tax appeals, including the Court of Appeals and the Supreme Court. Our attorneys are knowledgeable and our services are timely.

Executive Compensation, Qualified and
Nonqualified Deferred Compensation

With the enactment of Internal Revenue Code section 409A, the area of nonqualified deferred compensation has become a minefield for many of our clients. Our attorneys work with clients to develop executive compensation arrangements for their key employees that exceed their expectations, and to conform to the stricture of the Internal Revenue Code.

Federal Taxation

Our attorneys provide federal tax planning and advice to clients in the following areas:

  • entity formation, maintenance, dissolution and liquidation
  • joint ventures
  • mergers and acquisitions
  • executive compensation arrangements
  • qualified and nonqualified deferred compensation arrangements
  • asset protection
  • business succession planning
  • estate planning
  • trusts
  • gifting
  • probate

Estate Planning

We drafts wills, revocable trusts, irrevocable trusts, qualified personal residence trusts, grantor retained annuity trusts, gifting, education or care funds for family members, powers of attorney and health care directives. We help plan for full utilization of the federal and Washington State estate, gift and generation-skipping transfer taxes.

State and Federal Tax Law


Dean V. Butler

Dean V.

Estate Planning and Probate,
State and Federal Tax Law
George C. Mastrodonato

George C.

State and Federal Tax Law
Susan S. Schalla

Susan S.

Business Counseling and General Corporate
Mergers & Acquisitions, StartupsState and
Federal Tax Law, Estate Planning and Probate

Liberty B. Upton

Estate Planning & Probate
State & Federal Tax Law 
Joseph M. Wallin

Joseph M.

General Corporate,
Securities Law
Mergers & Acquisitions

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