REPRESENTATIVE EXPERIENCE
Michele’s extensive representative experience includes:
- Representing a Fortune 5 company in the defense of a North Carolina forced combination.
- Representing a large consulting firm in challenging the District of Columbia’s unincorporated business tax exclusion.
- Representing a Fortune 100 company challenging a characterization of a federal government contract for Washington state tax purposes.
- Representing one of the largest private companies in challenging Oregon’s application of its throwback rule.
- Representing numerous corporate clients in defending Maryland’s challenge of intangible holding companies.
PROFESSIONAL AND COMMUNITY INVOLVEMENT
- Member, American Bar Association
- Member, Taxation Section, District of Columbia Bar
- Member, American Institution of Certified Public Accountants
RECENT PUBLICATIONS AND SPEAKING ENGAGEMENTS
- Co-author, “The Supreme Court Should Accept a Nexus Case – Part II,” A Pinch of SALT, State Tax Notes (September 3, 2012)
- Co-author, “The Major League of Settlements: How to Pitch a Perfect Settlement,” A Pinch of SALT, State Tax Notes (November 7, 2011)
- Co-author, “D.C.’s Attempt to Force Remote Sellers To Collect Sales Tax,” A Pinch of SALT, State Tax Notes (July 11, 2011)
- Co-author, “California FTB’s Interested Parties Process Offers Taxpayers a Voice,” A Pinch of SALT, State Tax Notes (February 7, 2011)
- Co-author, “Understanding California’s New Apportionment Regime,” A Pinch of SALT, State Tax Notes (December 6, 2010)
- Co-author, “Combined Reporting—Amid All the Fuss There Are No Clear Winners,”
A Pinch of SALT, State Tax Notes (February 1, 2010)
- Co-author, “The Case of the Disappearing Dividends Received Deduction in California,” A Pinch of SALT, State Tax Notes (August 5, 2009)
- Co-author, “Overextending Attributional Nexus: States’ Latest Attempts to Tax Internet Sales,” A Pinch of SALT, State Tax Notes (March 2, 2009)
- Co-author, “California Restructures Its Corporate Income Tax,” Practical U.S./Domestic Tax Strategies (February 2009)
- Speaker, “A Bundle of Joy: What is a Bundle? How to Tax a Bundle? When to Un-Bundle?” COST Sales Tax Conference and Audit Session (February 24-27, 2013)
- Speaker, "Cloud Computing and Other Sales Tax Issues," The Bloomberg BNA Tax Policy and Practice Summit (November 13, 2012)
- Speaker, “Practical Guide to Handling State Tax Controversies,” 67th Annual TEI Conference (October 29, 2012)
- Speaker, “Cloud Computing,” State and Local Tax Roundtable (July 26, 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, "Income Tax Apportionment Trends," SALT Roundtable (May 10, 2012)
- Speaker, “Determining the Corporate Income Tax Base,” COST 2012 Intermediate/Advanced State Income Tax School (April 30, 2012)
- Speaker, “Ethics and Professional Responsibilities for Transactional Tax Professionals,” COST 2012 Sales Tax Conference and Audit Session ( March 5-7, 2012)
- Speaker, "2012 Legislation Update and Outlook" and "Defending Against or Applying Alternative Apportionment," TEI Florida Chapter State and Local Tax Session (February 28, 2012)
- Speaker, “Head in the Cloud: Applying Permanent Establishment, Nexus and Treaty Principles to Electronic Commerce Transactions,” TEI New Orleans: International Tax Developments Day (February 1, 2012)
- Speaker, Sutherland Inbound Roundtable (December 13, 2011)
- Speaker, “International Tax Developments – Safeguarding Against Tax Claims on Cross-border Principal” MAPI Tax Council II Meeting (November 17-18, 2011)
- Speaker, TEI Virginia Chapter - SALT Seminar (November 17, 2011)
- Speaker, “Impact of Federal Legislation and Other Uniformity Efforts on State Taxation,” National Premium Tax Annual Conference (November 15-17, 2011)
- Speaker, “E-Commerce and Cyberspace State Tax Issues: Use of Software & Data in a “Cloud” Environment,” “State Tax Litigation Tactics: A Review of Issues Associated with Statute of Limitations, Burdens of Proof and Establishing a Full Record,” TEI Arizona Chapter Meeting (November 8, 2011)
- Speaker, “Top 10 Practical Tips for Successfully Settling State Audits,” TEI Annual Conference (October 30-November 2, 2011)
- Speaker, “A Day in ‘Court’: Navigating the State and Local Appeal Process,” IPT Seattle (October 6, 2011)
- Speaker, “California Screamin’: A Review of Recent Changes to California Sales and Income Taxes,” “Reserves - Release or Forever?” “Significant State Tax Litigation Around the Country,” TEI Seattle Chapter Meeting (September 26, 2011)
- Speaker, “Latest and Greatest in State Tax,” “E-Commerce and Cyberspace State Tax Issues,” “Ask the Experts,” COST Pacific Northwest Regional Meeting (September 22, 2011)
- Speaker, “E-Commerce and Cyberspace State Tax Issues,” COST North Atlantic Regional State Tax Seminar (August 11, 2011)
- Speaker, “Current Issues in International Taxation,” TEI Houston Meeting (June 16, 2011)
- Speaker, “Cloud Computing - Focus on the Legal and Policy Issues,” FTA Meeting (June 13, 2011)
- Speaker, “Nexus – Update on Recent Developments: Current Standards, Emerging Trends and Significant New Legislation,” Florida Bar State Tax Conference (May 19-20, 2011)
- Speaker,“Top 11 State Income Tax Cases and Issues to Watch in 2011,” TEI Denver Chapter Meeting (May 18, 2011)
- Speaker, “Determining the Corporate Income Tax Base,” 2011 COST Intermediate/Advanced State Income Tax School (May 1-5, 2011)
- Speaker, TEI Atlanta Chapter Lunch (April 26, 2011)
- Speaker, “Review of the Source Rules, Permanent Establishment and Substantial Assistance” TEI Midyear Conference (April 3-6, 2011)
- Speaker, TEI Atlanta Chapter Lunch (April 1, 2011)
- Speaker, Tax Council Spring Conference (March 17-20, 2011)
- Speaker, “Colorado's Internet Use Tax and the Future of Internet Taxation,” Lorman Education Services Audio Conference (February 16, 2011)
- Speaker, “Litigation/Legislation Update,” “Sales Tax Developments, Including Taxation of Bundled Transactions and Digital Goods,” and “Reserves – Release or Forever?” TEI Seattle Chapter State and Local Tax Update (February 9, 2011)
- Speaker, “Discussion of Latest & Greatest State Tax Litigation,” Council on State Taxation (COST) Pacific Northwest Regional State Tax Seminar (June 17, 2010)
- Speaker, “Evolving Combined Reporting Issues,” COST Pacific Northwest Regoinal State Tax Seminar (June 17, 2010)
- Speaker, “Top Multistate Tax Issues of the Day for the Tax Executive,” Tax Executives Institute’s (TEI) 64th Annual Conference (October 25–28, 2009)
- Speaker, Southwest/West Regional Meeting of the Council on State Taxation (COST) (November 29, 2007)
- Co-presenter, “Filing Options,” IPT Income Tax Symposium (November 14, 2007)
- Co-presenter, State Tax Roundtable for Utilities and Power (November 8, 2007)
- Speaker, “Filing Methodologies (Unitary Business Principles)” and “Expense Disallowance/Attribution,” TEI 2007 State and Local Tax Course (August 20–24, 2007)
