Practice Areas

Federal Income Tax

Ryan’s Federal Income Tax professionals have a proven track record of minimizing, managing, defending, and controlling the federal income tax liabilities of many of the world’s largest global corporations.

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Ryan's Federal team is wonderful to work with, very professional and communicative.
Tax Director Major Business Services Corporation
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Federal Income Tax

Ryan’s Federal Income Tax practice assists clients with solutions that blend the right people, processes, and technology needed to efficiently and effectively manage and control federal income tax liabilities. Our seasoned tax professionals have real-world corporate tax experience to evaluate planned investments and provide expert opinions on possible tax implications, assisting our clients in addressing complicated tax issues with innovative solutions.

We assist clients in all phases of a tax controversy, from meeting with Internal Revenue Service (IRS) and Treasury officials to negotiating on behalf of a client in Appeals. And our proven approach is focused on building a shared vision with our clients, maintaining an open line of communication while aligning resources and delivering high-quality solutions customized to meet their unique needs.

Ryan TAARP—our proprietary tax account analysis review program—delivers incredible value and results related to conceptual issues involving interest law, statutes of limitations, claims for refunds, global interest netting, IRS transcription comprehension, and other IRS practice and procedure matters. Our value proposition is simple. We leverage our in-depth knowledge of foundational principles and cutting-edge legal and technical expertise to maximize recoveries, which enhance the effectiveness of our clients’ tax departments.

Ryan’s distinguished TAARP team includes former IRS attorneys and interest analysts who offer unparalleled expertise in securing interest refunds from the IRS and state tax authorities and resolving other tax account-related issues. We have served as expert witnesses, providing technical support in many of the most seminal court cases in this arena, and have testified in front of the United States Congress, IRS, and U.S. Department of the Treasury.

Chief Financial Officers expect the tax department to deliver the lowest possible tax liability allowed by law. While the utilization of tax-related transactions only increases complexity and costly risks in the tax-planning arena, Ryan’s Federal Income Tax planners pursue innovative and unique solutions.

Our global tax-planning and tax return review methodologies provide risk-free approaches for our clients. Our in-depth knowledge of tax code across all industries translates to optimal cash flow for our clients. From research and experimentation (R&E) credit studies, to Domestic Production Activities Deduction (DPAD) Internal Revenue Service (IRS) Code Section 199, to meals and entertainment studies, to accounting method reviews and/or change implementations, Ryan examines every complex opportunity to uncover often overlooked tax savings. 

A Captive Insurance Company (Captive) is a highly effective risk-management tool for businesses and their owners. A privately owned Captive Insurance Company insures the risks of its related entities by issuing policies, collecting premiums, and paying claims similar to a conventional insurer.

More than 80% of Fortune 500 companies utilize and benefit from Captives. With a Captive, insurance premium dollars are retained within the business enterprise or same “economic family,” thereby increasing investment income on unpaid loss reserves, capital, and surplus. Properly structured, a Captive may also provide substantial federal and state income tax savings.

Ryan has successfully facilitated a substantial number of Captive formations since introducing its Captive Insurance services. Ryan’s team of professionals provides all the administrative, regulatory, strategic, and operational support necessary to create and manage a Captive. Our Captive Feasibility Study assesses client data and business goals to determine viability based on costs and benefits. Leveraging these findings, we assist in the development of a detailed Captive business plan, strategically selecting and implementing the best Captive insurance structure to meet the client’s unique risk management needs. 

Taking full advantage of the R&E tax credit provides permanent cash tax savings to qualified companies. As opposed to research and development (R&D) deductions, R&E tax credits are actual dollar-for-dollar federal and state credits, available to businesses of any size involved in R&E activities. Many companies are not aware of the broad scope of activities that qualify for these credits. Evolving statutes, IRS regulations, and court cases continue to create R&E tax credit opportunities for an ever-widening range of qualified businesses.

The numbers are substantial. R&E tax credits in excess of $9 billion are claimed annually at the federal level alone. Businesses taking full advantage of these credits can recapture up to 20% of increased R&D expenditures. Often, there are additional opportunities to claim credits in years where the statute of limitations are open and obtain significant cash refunds or offset other defined withholdings. Even in circumstances where a client is generating operating losses and cannot currently take advantage of the R&E tax credit at the federal level, the state credit is often still applicable and beneficial. Some states offer refundable credits or other ways to monetize the credit (for example against payroll withholding).

Ryan helps clients navigate the complexities and mitigate the risks of the R&E tax credit, enabling businesses to remain innovative and profitable. With efficient and thorough methodologies that gather in-depth information with minimal disruption to our clients, Ryan accurately executes the three-phase credit process from start to finish at the federal and state levels. We develop and document nexus between qualified activities and costs, even where no accounting exists. We also stratify qualified research expenses (QREs) by risk, so clients can determine their individual risk tolerance.

Proper management and classification of fixed assets are critical to an organization’s tax management and compliance objectives. Improper capitalization of fixed assets can have a substantial negative impact on an organization’s balance sheet, resulting in missed tax savings and added compliance risks.

Ryan’s Fixed Asset Review service provides a comprehensive analysis of fixed assets to determine current asset classifications, ascertain depreciation reported in prior tax returns, and identify potential asset reclassification to ensure every appropriate tax deduction available is claimed. 

Ryan has a proven history of success identifying and securing substantial tax savings through cost segregation studies. Ryan’s Cost Segregation specialists identify and properly classify assets such as new construction or recent acquisitions. Our results are unmatched; we are typically able to reclassify up to 40% of our clients’ assets to business personal property. 

The 50% disallowance of the deduction for meals and entertainment (M&E) expenditures represents a significant, recurring permanent increase in taxable income. Often, companies inadvertently subject fully deductible M&E accounts to the 50% disallowance, resulting in a higher effective tax rate. Ryan’s M&E review is designed to quickly understand a company’s policies and procedures for M&E tax accounting, and to calculate and document the correct amount of non-deductible M&E in the current and prior tax periods. If the size of the data set warrants it, we utilize IRS standard statistical sampling methods to aid in determining the non-deductible M&E. The benefits achieved may include considerable refunds of prior years’ taxes and ongoing permanent tax savings, while providing improvements to our clients’ processes and procedures to appropriately segregate fully deductible expenditures from otherwise partially deductible M&E costs.

Ryan understands the importance of risk mitigation in today’s tax environment and offers support for IRS audit readiness and the IRS examination process. Our IRS Audit Readiness services assess audit risks, evaluate tax positions taken on returns, identify and document Internal Revenue Code (IRC) Section 6662(e) voluntary adjustment submissions, file amended returns, and work with the IRS on developing a joint examination plan.

Our IRS Audit Support services help clients plan and manage an ongoing examination, helping clarify and resolve audit issues. We assist from the opening conference to responding and tracking Information Document Requests. We make strategic recommendations and help implement various alternative resolutions. Ryan serves as a complete client advocate all the way through to the closing examination conference. Additionally, Ryan’s Federal Income Tax practitioners have significant IRS appeals experience and assist in every phase of a tax controversy, from meeting with IRS and Treasury officials to negotiating on behalf of a client in appeals. 

Ryan’s diligent approach to tax accounting delivers strategic solutions that enable our clients to proactively manage their overall federal income tax positions. Ryan professionals include former Fortune 100 tax executives who have designed and managed corporate tax accounting matters, including Accounting Standards Codification (ASC) 740 and all of the Sarbanes-Oxley processes and controls. Since Ryan is not a certified public accounting (CPA) firm, we are free to consult with tax departments regarding ASC 740 issues and assist with workflow optimization. To evaluate client risk and enhance processes, Ryan’s Tax Accounting service professionals:

  • Determine and review valuation allowances and admissibility of deferred tax assets
  • Assist with tax provisions and tax-basis balance sheets
  • Identify and measure tax risks and Units of Accounting impacting the organization
  • Design and implement new processes and systems, tax provision software integration, and training in ASC 740 theory and practice

Process and technology have become critical to a more efficient and effective corporate tax practice. Ryan professionals work with clients to transform their tax function from a mere compliance group to a strategically focused department by implementing critical processes that tap the full potential of new and existing tax technology solutions.

Ryan evaluates and analyzes existing tax compliance and reporting processes, making recommendations that enhance and streamline operations. We work in tandem with our clients to implement best practice solutions while installing the proper quality assurance controls. As a result, tax departments improve efficiency, gain greater control, substantially mitigate risk, and add tremendous strategic and financial value to their organizations.

Tax return preparation and other compliance services are essential responsibilities in every tax department. Increased regulatory scrutiny makes it more important than ever to determine tax positions as early as possible in the reporting cycle. As a result, companies are forced to spend more time and energy on the compliance process, often at the expense of higher value initiatives.

Ryan’s Federal Income Tax Compliance solutions are tailored to fit specific client requirements, whether completing a tax form based on information provided or preparing the entire tax return from start to finish. Our consultants leverage vast expertise in tax technology and project management to provide comprehensive automation solutions and unparalleled quality assurance. 

Integrated End-to-End Tax Services

Ryan is focused on your overall tax performance—providing innovative solutions to the underlying causes of the errors we identify—and creating greater opportunities to measure and improve your efficiency, develop a more strategic approach to tax, and deliver outstanding value to your shareholders.