REPRESENTATIVE EXPERIENCE Jeff’s extensive representative experience includes:
- Representing a Fortune 50 technology corporation in multistate income tax audit defense, including business and nonbusiness income issues.
- Serving as national multistate tax counsel to a leading cable television provider including assisting in resolving numerous multistate tax audits spanning business and nonbusiness issues, and serving as national counsel before the Multistate Tax Commission (MTC) on various state income tax matters.
- Assisting a Fortune 100 telecommunications company in coordinating its national controversy and litigation regarding challenges to state tax allocation positions associated with certain business transactions.
- Developing and implementing a multistate tax strategy to address intercompany debt and other issues impacting state income tax apportionment for a multi-billion dollar corporation.
- Providing a broad range of state tax consulting and audit defense for a leading global technology services provider.
- Engaging in state tax policy advocacy efforts, including for national and state legislative initiatives, on behalf of various retail clients.
- Successfully intervening on behalf of the state of Florida in a case involving the constitutionality of a tax on satellite television.
- Testifying before the U.S. State Finance Committee on state tax matters.
- Representing the United States at the Organization for Economic Cooperation and Development.
PROFESSIONAL HONORS AND AWARDS
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2012)
- Recognized by The Legal 500 United States in the area of tax controversy (2011)
- Recognized among State Tax Notes’s “People to Watch,” individuals who have already played an important role but will likely dominate the field in the next 10 years. Jeff was described as having extensive experience “in many areas, including corporate, sales, franchise, and even unclaimed property.” (January 2010)
- Selected for inclusion in the PLC Which Lawyer? Yearbook in the area of tax (2008)
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Adjunct Professor, Georgetown University Law Center's State and Local Tax course offered as part of its LL.M. program
- Faculty Member, Council On State Taxation Income Tax School and the Tax Executives Institute’s State and Local Tax School
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- Co-author, “Applying False Claims Acts in State Taxation,” A Pinch of SALT, State Tax Notes (May 7, 2012)
- Co-author, “Friends With Benefits Received? A Comparison of Market Sourcing Rules,” State Tax Notes (December 5, 2011)
- Co-author, “D.C.’s Attempt to Force Remote Sellers To Collect Sales Tax,” State Tax Notes (July 11, 2011)
- Co-author, “Waive or Walk: Considerations for Extending the Statute of Limitations,” A Pinch of SALT, State Tax Notes (November 1, 2010)
- Co-author, "Applying P.L. 86-272 In a Modern Economy," A Pinch of SALT, State Tax Notes (July 5, 2010)
- Co-author, “State Tax Issues Resulting From IRS Announcement 2010-9,” A Pinch of SALT, State Tax Notes (May 3, 2010)
- Co-author, "State RAR Reporting—Simplifying Unnecessary Complexities," A Pinch of SALT, State Tax Notes (March 1, 2010)
- Co-author, “Employment Tax Withholding Compliance: Sorting Through a Patchwork of Laws,” Partnering Perspectives (Winter/Spring 2010)
- Co-author, "The U.S. Supreme Court Should Accept a Nexus Case," A Pinch of SALT, State Tax Notes (July 9, 2009)
- Author, “The Redemption of Equitable Apportionment,” The Tax Executive (September–October 2006)
- Co-author, “Check Your California Receipts: California Supreme Court Should Provide Appropriate Standards For Equitable Apportionment,” Tax Analysts (September 5, 2005)
- Co-author, “Filling State Coffers,” Legal Times (October 25, 2004)
- Speaker, “Determining the Corporate Income Tax Base,” Council On State Taxation Intermediate/Advanced State Income Tax School (April 29, 2013)
- Speaker, “Transaction Tax Cases and Issues to Watch in 2013,” COST Sales Tax Conference and Audit Session (February 24-27, 2013)
- Speaker, “Legislative and Administrative Developments in State Taxation,” The National Multistate Tax Symposium (February 6-8, 2013)
- Speaker, “Around the World in 120 Minutes: Year-End Corporate Tax Round-Up,” TEI/Thomson Reuters Webcast (December 13, 2012)
- Speaker, “The Cats and Dogs of Sales Tax: Bundling, Absorption and Other Furry Creatures,” COST Pacific Northwest Regional Meeting (December 4, 2012)
- Speaker, “Review and Preview of Federal Constitutional Issues,” New York University Institute on State and Local Taxation (November 30, 2012)
- Speaker, “State Tax Aspects of Attorney Client Privilege and Work Product Doctrine,” State Tax Roundtable for Utilities and Power (STARTUP) (November 9, 2012)
- Speaker, “National Developments and Trends in State Taxes – Point/Counterpoint Discussion,” MACPA/Maryland Bar Association Advanced Tax Institute (November 8, 2012)
- Speaker, “A SALTy Countdown – the Top 10 Litigation Cases of 2012,” California State Bar Association 2012 California Tax Policy Conference (November 2, 2012)
- Speaker, “Significant Court Decisions Impacting Our Industry” and “Seeking State Tax Fairness: The Need for Federal Adjudication, A Taxpayers Bill of Rights and Federal Preemption Legislation,” Broadband Tax Institute Annual Conference (October 21, 2012)
- Speaker, “State and Local Tax Update,” TEI Seattle Chapter Meeting (September 19, 2012)
- Speaker, “Cloud Computing,” State and Local Tax Roundtable (July 26, 2012)
- Speaker, “Leveling the Playing Field,” Southeastern Association of Tax Administrators Annual Conference (July 24, 2012)
- Speaker, “State Tax Roundtable – Planning and Techniques,” TEI Region VII Conference (June 27-July 1, 2012)
- Speaker, “How the Interstate Tax System Works: Jurisdiction and Nexus,” Interstate Tax Planning Meeting (June 27, 2012)
- Speaker, “Cloud Computing Developments,” FTA Annual Meeting (June 17, 2012)
- Speaker, “State Tax Update,” TEI Region VIII Tax Conference (June 11, 2012)
- Speaker, “State Tax Litigation Update,” North Carolina Bar Association (May 25, 2012)
- Speaker, “Transfer Pricing and Intercompany Transactions,” TEI Denver: State and Local Taxation Update (May 16, 2012)
- Speaker, “Top Ten Reasons for Inconsistencies: Multistate Corporate Taxpayers and Varied State Laws,” COST 2012 Spring Audit Session/Income Tax Conference (May 15-18, 2012)
- Speaker, "State and Local Tax Update," SALT Roundtable (May 10, 2012)
- Speaker, “Document Management Retention,” STARTUP Meeting (May 9, 2012)
- Speaker, "Alternative Apportionment," TEI Houston (May 3, 2012)
- Speaker, “Determining the Corporate Income Tax Base,” COST 2012 Intermediate/Advanced State Income Tax School (April 30, 2012)
- Speaker, “Hey You! Get Off My Cloud!,” TEI: 62nd Midyear Conference (March 25-28, 2012)
- Speaker, “State Tax Litigation Update” and “Defending Against or Applying Alternative Apportionment,” TEI Florida Chapter State and Local Tax Session (February 28, 2012)
- Speaker, “State and Local Tax M&A Issues,” TEI Dallas Chapter Meeting (February 21, 2012)
- Speaker, “Legislative Developments in State Taxation," The National Multistate Tax Symposium (February 3, 2012)
- Speaker, “Mergers and Acquisitions,” NYU Institute on State and Local Taxation (December 12-13, 2011)
- Speaker, TEI Virginia Chapter SALT Seminar (November 17, 2011)
- Speaker, “Settled Expectations: Best Practices to Negotiate and Memorialize State Tax Settlements,” TEI Philadelphia Chapter Meeting (November 9, 2011)
- Speaker, “State and Local Taxation – Recent Developments,” Tulane 60th Annual Tax Institute (October 26-28, 2011)
- Speaker, “A Day in "Court": Navigating the State and Local Appeal Process,” IPT Seattle (October 6, 2011)
- Speaker, “Top Ten Guidelines for Negotiating a Good State Tax Settlement,” “State Tax Consequences of Federal Uncertain Tax Positions,” California Screamin': A Review of Recent Changes to California Sales and Income Taxes,” TEI Seattle Chapter Meeting (September 26, 2011)
- Speaker, “Latest and Greatest in State Tax,” “E-Commerce and Cyberspace State Tax Issues,” “Ask the Experts Panel,” COST Pacific Northwest Regional Meeting (September 22, 2011)
- Speaker, “State Tax Policy Update: 2011 and Beyond, including the Best and Worst of Property Tax Administration: Scorecard on State Property Tax Administrative Practices,” COST North Atlantic Regional State Tax Seminar (August 11, 2011)
- Speaker, “Use Tax Collection Issues and Developments,” MTC 44th Annual Conference (July 24-28, 2011)
- Speaker, “Retroactive Tax Legislation,” IPT Annual Conference (June 26-29, 2011)
- Speaker, “State Tax Roundtable – Planning and Techniques,” TEI Region VII (June 22-25, 2011)
- Speaker, “How the Interstate Tax System Works” and “Jurisdiction and Nexus,” Interstate Tax Corporation Interstate Tax Planning Seminar (June 20-22, 2011)
- Speaker, “Cloud Computing - Focus on the Legal and Policy Issues,” Federation of Tax Administrators Annual Meeting (June 12-15, 2011)
- Speaker, “Top 11 State Income Tax Cases and Issues to Watch in 2011,” COST 2011 Spring Audit Sessions/ Income Tax Conference (May 22-25, 2011)
- Speaker, “Top 11 State Income Tax Cases and Issues to Watch in 2011,” TEI Denver Chapter Meeting (May 18, 2011)
- Speaker, Manufacturers Alliance MAPI Tax Council II Meeting (May 5, 2011)
- Speaker, “Waive or Walk: Considerations for Extending the Statute of Limitations,” TEI Midyear Conference (April 3-6, 2011)
- Speaker, Webinar: Codified Economic Substance Doctrine: You'll Know It When You See it? A Guide to Navigating The New Economic Substance World (March 30, 2011)
- Speaker, “Litigation/Legislation Update,” “Intercompany Accounting Issues,” “Sales Tax Developments,” “Economic Substance and Reportable Transactions,” and “Reserves – Release or Forever?” TEI Seattle Chapter State and Local Tax Update (February 9, 2011)
- Speaker, “Pending State Tax Legislation,” National Multistate Tax Symposium—Multistate Tax: Navigating an Economy in Transition (February 2-4, 2011)
- Speaker, “Attributional Nexus Developments for State Income, Sales/Use and Gross Receipts Taxes—Reconciling Bellas Hess and Quill with Scripto and Tyler Pipe,” Council on State Taxation (COST) 41st Annual Meeting (October 19-22, 2010)
- Speaker, “Multistate Tax Update: Digital and Other Difficult Tax Issues,” Institute for Professionals in Taxation (IPT) Wisconsin One-Day Tax Seminar (September 23, 2010)
- Speaker, “Significant Decisions Impacting Our Industry,” Broadband Tax Institute 2010 Annual Conference (September 19-22, 2010)
- Speaker, “State Tax Roundtable—Planning and Techniques,” TEI Region VII Conference (July 22-25, 2010)
- Speaker, “How the Interstate Tax System Works/Jurisdiction and Nexus and the Unitary Concept,” Interstate Tax Corporation’s Interstate Tax Planning Conference (June 21, 2010)
- Speaker, “Discussion of Latest & Greatest State Tax Litigation,” Council on State Taxation (COST) Pacific Northwest Regional State Tax Seminar (June 17, 2010)
- Speaker, “Digital Age SALT Issues—Applying Old Rules to New Technology,” COST Pacific Northwest Regional State Tax Seminar (June 17, 2010)
- Speaker, “Evolving Combined Reporting Issues,” COST Pacific Northwest Regional State Tax Seminar (June 17, 2010)
- Speaker, STARTUP Spring 2010 State Tax Roundtable for Utilities and Power (April 28, 2010)
- Speaker, "Determining the Corporate Income Tax Base," Council on State Taxation (COST) Intermediate /Advanced State Income Tax School (April 25-29, 2010)
- Speaker, "State Taxation" and "International Operations Trends and Dangers," The Tax Council 2010 Annual Spring Conference (March 27, 2010)
- Speaker, “Combined Reporting,” Tax Executives Institute (TEI) NY Chapter Meeting – State Taxation update (February 24, 2010)
- Speaker, “Pending State Tax Legislation,” The National Multistate Tax Symposium Multistate Tax Planning After the Storm (February 5, 2010)
- Speaker, “State and Local Tax Developments – The Dangers of Unreliable Intercompany Accounting in Separate Company States and Other Issues,” Tax Executives Institute (TEI) Webinar Learning Network(January 12, 2010)
- Speaker, “State-Tax Planning – Even More Important Now,” COST Mid-Atlantic Regional Tax Seminar (December 21, 2009)
- Speaker, “State-Tax Planning – Ouch & Likely Getting More Painful,” COST Mid-Atlantic Regional Tax Seminar (December 21, 2009)
- Speaker, “Penalties – How to Avoid Them, How to Contest Them,” NYU 28th Institute on State and Local Tax (December 15, 2009)
- Speaker, “National Developments and Trends in State Taxes – Point/Counterpoint Discussion,” Maryland Institute for Continuing Professional Education of Lawyers (MICPEL) and Maryland Association of CPAs (MACPA) Advanced Tax Institute (November 5, 2009)
- Speaker, “State Tax Issues for Distressed Companies,” TEI 64th Annual Conference (October 27, 2009)
- Speaker, “Significant Decisions Impacting Our Industry,” The Broadband Tax Institute (BTI) Annual Conference (October 19, 2009)
- Speaker, “Wisconsin Combined Reporting: Background and Discussion Regarding Taxpayer Issues,” COST Mid-West Regional State Tax Seminar (October 1, 2009)
- Speaker, “State Tax Roundtable – State Tax Planning and Developments,” TEI Region VII Meeting (June 9, 2009)
- Speaker, “State and Local Tax Planning and Unplanning,” TEI 58th Midyear Conference (March 30, 2009)
- Speaker, “State Attacks on Inter-Company Transactions,” TCPI Conference (February 25, 2009)
- Speaker, “Looking Forward—Sales Tax Impact of Federal Legislation,” The 2009 National Multistate Tax Symposium (February 4, 2009)
- Speaker, Tax Executives Institute Houston Chapter (February 2, 2009)
- Speaker, “Penalties—Automatic? Amnesty? Heavy Handed?” New York University Conference 27th Institute on State and Local Taxation (December 16, 2008)
- Speaker, “Significant Federal & State Decisions That Impact Telecommunication,” Broadband Tax Insititute (October 20, 2008)
- Speaker, “Ethical & Practical Considerations in Accounting for Income Taxes,” 15th Annual Paul J. Hartman SALT Forum (October 28, 2008)