REPRESENTATIVE EXPERIENCE Jeff’s extensive representative experience includes:
- Representing a Fortune 50 technology corporation in multi-state income tax audit defense, including business and nonbusiness income issues.
- Serving as national multi-state tax counsel to a leading cable television provider including assisting in resolving numerous multi-state 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 multi-state 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
- 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 Executive Institute’s State and Local Tax School
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- 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, “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 Regoinal State Tax Seminar (June 17, 2010)
- Speaker, “Evolving Combined Reporting Issues,” COST Pacific Northwest Regoinal 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,” (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)