Andrew (Andy) L. Howlett

Andy Howlett employs a results-oriented approach to help businesses and individuals meet their federal income, estate, gift, and excise tax challenges, delivering value by helping taxpayers anticipate, plan for, and navigate the vagaries of the Internal Revenue Code. In era of a hyperspecialization, he remains a federal tax generalist, helping clients see the "big picture" of federal tax laws, and identify opportunities for tax efficiency across many, often overlapping, areas of the Code. 

With respect to federal income taxes, Mr. Howlett has experience on a wide range of domestic and cross-border transactions. He has advised clients on asset and stock purchases, joint ventures, mergers, recapitalizations, and spin-offs, helping clients understand and plan for the tax consequences of these transactions through drafting operative documents as well as through providing informal and formal advice (including written tax opinions). Mr. Howlett has worked with taxpayers to navigate key changes brought about by the Tax Cuts and Jobs Act of 2017 and the Inflation Reduction Act, including the 20 percent passthrough deduction under section 199A and producer, manufacturer, and consumer tax credits relating to green energy. He has also represented taxpayers in federal income tax proceedings in front of Internal Revenue Service (IRS) Appeals and has negotiated favorable resolutions of disputed complex federal tax issues with the IRS.

A significant part of Mr. Howlett's practice involves federal tax planning and administrative controversy issues that arise with trusts. In recent years, he helped a domestic non-grantor trust navigate the transfer and sale of closely held stock in a tax efficient way, ensured that foreign trusts with U.S. investments and beneficiaries complied with their reporting requirements (including Foreign Bank Account Reporting (FBAR), the Foreign Account Tax Compliance Act (FATCA), and Form 3520), and obtained a favorable IRS letter ruling for a trustee on a transaction designed to minimize a grantor's potential federal gift and estate tax exposure. On the controversy side, Mr. Howlett represented trusts in voluntary disclosures as well as in administrative controversies before IRS Appeals on a variety of issues, including the imposition of reporting penalties and the applicability of the passive foreign investment company (PFIC) rules.

Mr. Howlett has represented individual taxpayers on federal income tax matters and has substantial experience helping taxpayers "come into compliance" through the IRS's voluntary disclosure programs.

He has substantial experience with a broad spectrum of federal excise taxes, assisting taxpayers in understanding their excise tax obligations, structuring their affairs to minimize excise tax liability, and taking advantage of various excise tax credits. He has represented taxpayers in controversy matters with respect to excise tax disputes with the IRS.

As part of his work, he regularly advises clients on the reporting and ethical requirements of the tax practice, including the rules relating to reportable transactions and Circular 230.

Mr. Howlett maintains a dedicated and vibrant pro bono practice, primarily advising non-profits on how to obtain and maintain tax-exempt status under the Code. In addition to his professional work, he is active as an officer or director in numerous organizations, including the Legal Aid Justice Center (Director), Beta Omicron Chapter of Delta Tau Delta Fraternity (Treasurer), and the Miller & Chevalier Foundation (Director).