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Montere R. Wuensche maintains a broadly-based tax planning and tax controversy practice. He has significant experience in structuring complex transactions and in resolving disputes with the IRS for clients including individuals and public, private and multi-national businesses. 

 In his tax planning practice, Mr. Wuensche works with tax executives and in-house counsel as well as financial and operating personnel, to identify and anticipate tax issues that may also affect other legal disciplines such as corporate law. 

In controversy matters, Mr. Wuensche seeks to find practical, cost-effective resolutions to client issues with a focus on the long-term implications.  Although adept at resolving issues at the audit or IRS Appeals level, when such resolution is not possible, he has successfully represented clients in the courts of competent jurisdiction.

Significant Transactions

• Obtained Private Letter Ruling from IRS regarding F reorganization of S Corporation
• Facilitated numerous corporate tax-free reorganizations
• Prepared Competent Authority Request for multi-national corporation
• Assisted international corporate clients in establishing, documenting, and defending intercompany transfer pricing strategies and policies
• Resolved multi-million dollar property tax dispute with Montgomery County
• Negotiated and prepared Property Development Agreement for major residential construction project
• Prepared and implemented sale to an intentionally defective grantor trust
• Negotiated and implemented purchase of local private school
• Established and funded numerous family limited partnerships
• Established numerous charitable foundations and assisted in obtaining tax-exempt status from the IRS
• Tax controversy matters include issues ranging from hobby losses, business deductions, valuation of family limited partnerships, trust-fund recovery penalties and valuation of timber
• Established numerous corporate entities and implemented numerous exit-strategies including buy-sell agreements
• Performed domestic and international estate planning for individuals including preparation of wills, trusts, and powers of attorney
• Prepared and filed numerous federal estate and gift tax returns

Seminars & Presentations 

• "Statutory and Non-Qualified Stock Options"
• "S Corporation Stock – Now that I have it, what do I with it?"
• "Are Your Client's Workers Employees or Independent Contractors"
• "The Section 199 Domestic Production Activities Deduction"
• "Contract Manufacturing and Subpart F"
• "Estate Planning for the Family Business and its Owners"

Professional Affiliations

• Houston Bar Association
• American Bar Association
• Member, Lamb & Goat Auction Committee, Houston Livestock Show & Rodeo