Browne, Garrett

Kevin has provided tax counsel for entity formations, private and public offerings, mergers, acquisitions and tender offers, as well as structuring numerous other business transactions including divisive reorganizations and recapitalizations. Kevins taxation practice also includes the representation of entities and individuals regarding deferred compensation plans, qualified and nonqualified stock option plans, audits, abatement proceedings and refund actions.

Kevins trust and estate representation involves the implementation of efficient transfer of assets and preservation of wealth, including the planning of asset transfers among family members both during lifetime and upon death. Kevins practice in this area is driven to accomplish both clients long-term goals as well as the minimization of income, gift and estate taxes. Kevins experience includes the representation of high net worth individuals, trust departments for national and state banks, representation of estates in probate proceedings, and representation of trusts and estates before tax authorities and in litigation. Kevins experience also includes the establishment of a trust department for a national bank as well as providing advice regarding bank common trust funds and collective investment funds.

Kevins representation of clients with regard to ERISA issues has involved both the implementation and amendment of qualified plans, advice regarding the structure and implementation of ESOP plans as a corporate finance tool, advice regarding plan operational and administrative issues, as well as the termination of qualified plans resulting in the recovery of excess benefits. Kevin has also provided representation before the Internal Revenue Service and the Department of Labor for determination letters and audits.

Kevins tax controversy experience includes the representation of businesses, individuals, estates, trusts, and retirement plans before the Colorado Department of Revenue, Internal Revenue Service, State District Courts, federal District Courts, United States Tax Court, and the United States Circuit Courts of Appeal.