Law Office of
James B. Mann
James Mann has unmatched broad-based business tax experience which provides the foundation for his current focus on cannabis tax. Most of his current clients are cannabis companies, some publicly traded, some with aspirations to being publicly traded in the near future, and some are privately held and intend to remain that way for now. Mr. Mann helps these clients with tax planning to minimize current tax liability (restructuring, tax accounting, revising intercompany agreements, transfer pricing) as well as representing them before the IRS and in court.
Mr. Mann has done tax planning for large corporations and financial institutions as well as partnerships and high net worth individuals. His tax experience includes work at large financial institutions, public accounting firms, large law firms and specialized tax firms. His work has included planning and structuring complex transactions as well as audit work and tax litigation. His tax litigation experience includes both taxpayer work (including arguing the significant Harborside cannabis case in the 9th Circuit Court of Appeals) as well as litigation on behalf of the Tax Division of the Department of Justice.
Mr. Mann is frequently quoted in the tax press with respect to cannabis tax, the 16th Amendment, opportunity zones, wealth taxes, and cryptocurrency, among other issues.
Tax code Section 482 is usually associated with multinational corporations and transactions between member entities located in different national jurisdictions. David Merrick of Riverbank Consulting and James Mann of the Law Office of James B. Mann show how it applies to cannabis businesses operating in multiple states in Part 1 of a two-part article.
Tax code Section 482 is usually associated with multinational corporations and transactions between member entities located in different national jurisdictions. David Merrick of Riverbank Consulting and James Mann of Law Office of James B. Mann walk through transfer pricing methods and explain what works and what doesn’t for the cannabis industry.
On March 30th, 2020 the Treasury Inspector General for Tax Administration (TIGTA) released a report — “The Growth of the Marijuana Industry Warrants Increased Compliance Efforts and Additional Guidance.”
Recently, the Supreme Court denied a petition for a writ of certiorari appealing from the 10th Circuit decision in Standing Akimbo, LLC v. United States, 955 F.3d...