Tax Planning Attorney · Nashville
Planning is what decides the return.
Preparation files what already happened.
Tennessee tax planning for $2M to $50M businesses, founders, and family-owned operating companies.
By Knight Lancaster, JD, CPA · Last reviewed May 2026
The leverage sits in the spring, the summer, and the fall.
Tax planning is the legal and financial work that decides what shows up on the return. Tax preparation is the filing of what already happened. Most clients come to the planning conversation in March, when the year is closed and the return is due. The leverage is gone by then.
Real planning sits before the entity election deadline, before the stock grant, before the transaction closes, before the gifting decision. Knight Lancaster is a Tennessee attorney and a licensed CPA. The Lancaster CPA Firm prepares the corporate, partnership, trust, gift, and personal returns that come out of the planning work — so the strategy conversation, the document, and the return all agree at the line.
What Tennessee tax planning covers.
Six categories. The same firm handles each one, and the planning gets coordinated against the same set of facts.
Federal Income Tax
Multi-year strategy for the client who pays at both levels.
Loss harvesting, basis planning, timing of recognition events, retirement-account contribution strategy, and ongoing federal compliance review for the client who pays both individual and entity-level tax.
Business Tax
Entity choice, §199A, reasonable comp, accountable plans.
Entity choice and conversion analysis, §199A pass-through deduction optimization, reasonable compensation on S-corp owners, accountable plans for owner-employees, and the F&E impact of structural decisions.
Tennessee SALT
Franchise, excise, residency, sales-and-use.
Franchise and excise tax planning for entities, residency planning for inbound and outbound moves, sales-and-use structure and compliance on multistate transactions.
Transactional
The deal structure decides the after-tax check.
Asset versus stock, §338(h)(10) elections, F-reorganization, §351 rollover deferral on transaction equity, §1202 QSBS qualification and the five-year holding period.
Wealth Transfer
Exemption sunset, GRATs, IDGTs, family LLC discounts.
Gift and estate tax strategy on a closely held business interest, the federal exemption sunset timing, GRATs, IDGTs, family LLC valuation discounts, and the Tennessee Community Property Trust as a basis-step-up tool.
IRS & TN DOR Controversy
When the planning meets the audit.
Preparation, response, compliance review, and resolution before the IRS and the Tennessee Department of Revenue, on behalf of the client who needs the strategy conversation protected.
Tennessee tax law, used the way it's written.
Tennessee tax law is friendlier than most states for residents and operating businesses, but the friendliness has shape. The page is for owners who want to use it.
The provision
No state income tax
What it does
Tennessee has no individual income tax (the Hall Tax on interest and dividends was fully repealed in 2021). For high-income individuals planning a residency change to Tennessee, the savings are real and immediate. Domicile establishment matters — driver's license, voter registration, banking, and charitable affiliations all support the residency claim if it is later examined.
The provision
Franchise and excise tax
What it does
Tennessee imposes a franchise tax (0.25% of net worth, post-reform) and an excise tax (6.5% of net earnings) on most business entities. The base, the apportionment, and the entity classification all affect the bill. Knight serves on the Tennessee Society of CPAs State and Local Tax Committee, which follows the Department of Revenue's positions on F&E.
The provision
Tennessee Community Property Trust
What it does
A Tennessee-specific tool that gives married couples a full step-up in basis at the death of the first spouse on assets transferred into the trust. For appreciated equity (closely held business interests, low-basis securities, real estate), the basis savings can be substantial.
The provision
Remote Online Notarization
What it does
Tennessee RON lets us complete tax-planning signings — trust funding, deed transfers, gift documentation — for clients across the state without an in-person trip to Nashville.
"Planning is what decides the return. Preparation files what already happened."
Business owners, individuals, and the deal on the calendar.
Most of the leverage in business tax planning is in the year before the leverage gets used. Owners taking over $200K in pass-through profit are leaving the §199A deduction on the table when the business income is not properly characterized. S-corp owners taking sub-market salaries are sitting on an audit issue. C-corp founders who never analyzed §1202 QSBS are passing up the federal capital-gains exclusion of up to $10M or 10x basis on a future sale. Each of those is a planning conversation that runs alongside entity formation and business succession.
The personal return is where the planning lands. Capital gains harvesting against losses, AMT planning, charitable giving structured for itemized deduction or DAF efficiency, retirement-account strategy across IRA, 401(k), and SEP options, and the §83(b) election thirty-day window for founder equity. For owners with significant assets, the wealth-transfer side runs through gift, estate, and trust planning — the federal estate-tax exemption sunset is a live issue.
When a sale or acquisition is twelve to twenty-four months out, the planning window is open. The deal structure (asset, stock, §338(h)(10), F-reorganization, rollover) decides the after-tax check more than the headline price does. §1202 QSBS qualification has a five-year holding period that has to start before the deal, not after. For deal-side mechanics, see the M&A practice page.
Why a tax planning attorney instead of a CPA alone.
A CPA can save you money on your return. A tax planning attorney can build the strategy that produces the return — and defend it in court if the IRS asks questions later. Aggressive positions, contingent assets, residency claims, partnership allocations, the §1202 holding clock, the gift the family is about to make: these are legal positions before they are tax filings.
There is one thing to know about how Knight works. Strategy conversations with a tax attorney are protected by attorney-client privilege. If the same attorney also prepares the return, the act of preparation is not privileged work — it is accounting. Knight offers two paths: (a) the strategy work alone, fully under privilege, with another firm preparing the return; or (b) the strategy plus the preparation, under one roof, accepting that the preparation work itself is not privileged.
Either way, the value is the same: better strategy because a lawyer designed it, and a lawyer who can stand behind it if the position is ever examined.
Every planning decision has a return underneath it. The §199A calculation, the S-corp comp split, the §1202 holding clock, the franchise-and-excise base, the gift-tax Form 709 — all of it lands on a return Knight would prepare. As a CPA, he sees the legal position and the line item at the same time, so the strategy conversation, the document, and the filing agree at the line. Tennessee bar admitted, dually licensed as a Certified Public Accountant, recognized in Best Lawyers in America.
The plan, the document, and the return that follows from it.
Tax planning, answered.
What is the difference between tax planning and tax preparation?
Tax planning is the legal and financial work that decides what shows up on the return: entity choice, comp structure, deal structure, gifting decisions, retirement-account strategy. Tax preparation is the filing of the return at year-end, after the planning decisions have already been made. Most of the leverage is in the planning phase. Tax preparation files what already happened.
Is a tax attorney better than a CPA?
The two roles do different work and the better answer is usually both. A CPA prepares returns, runs financial statements, and handles the accounting and compliance side. A tax attorney provides legal advice on tax positions, drafts the documents that implement planning, and protects strategy conversations under attorney-client privilege. Knight is licensed as both, which means the planning conversation, the document drafting, and the resulting return preparation happen under one roof.
How much does a Nashville tax planning attorney cost?
Hourly rates for tax planning attorneys in Nashville generally run $300 to $700+ depending on firm and seniority. Lancaster Law works on a flat-fee basis for defined-scope tax planning engagements (entity analysis, §1202 evaluation, residency planning, year-end packages) and hourly for open-ended advisory or controversy work. We quote a specific dollar amount after the first conversation.
When should I start tax planning?
The general rule is twelve months before the event the planning is meant to affect. If the event is a year-end recognition decision, planning should start in the third quarter. If the event is a sale of the business, planning should start twelve to twenty-four months before close. If the event is a gift to the next generation, planning should start in the year of intended transfer. The earlier the planning, the more levers an owner has.
Does Tennessee have a state income tax?
No. Tennessee has no individual income tax (the Hall Tax on interest and dividends was fully repealed in 2021). The state generates revenue from sales tax, franchise and excise tax on business entities, and property tax. For high-income individuals planning a residency change to Tennessee, the savings on state income tax are real and immediate, but domicile establishment matters and the move has to be supported by the legal record.
Reviewed by Knight Lancaster, JD, CPA, MBA
Knight Lancaster is the founder of Lancaster Law, P.C. and The Lancaster CPA Firm, P.C. in Nashville, Tennessee. He is one of a small number of attorneys in Tennessee who is also a licensed CPA, giving him a dual perspective on the legal documents and the tax returns that follow them. Knight has been recognized in Best Lawyers in America, Ones to Watch (Corporate Law), in 2023 and 2024, and serves on the Board of Directors of the American Academy of Attorney-CPAs. He is a member of the Tennessee Society of CPAs State and Local Tax Committee. He earned his JD and MBA from Belmont University (the first graduate of Belmont's joint JD/MBA program) and a BS in Accounting from the University of Tennessee. Before founding Lancaster Law, Knight practiced at Bone McAllester Norton (now Spencer Fane), where his work focused on mergers, acquisitions, dispositions, and securities matters.
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This article is for educational purposes only and is not legal advice. Reading it does not create an attorney-client relationship. For advice specific to your situation, contact Lancaster Law directly.
Tennessee Bar
Practicing since 2019
Triple credential
JD · CPA · MBA
Peer-reviewed
Best Lawyers, Ones to Watch, 2023 + 2024
TSCPA SALT Committee
Tennessee Society of CPAs
Tax counsel across Tennessee.
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