Obtained favorable settlements with the California Franchise Tax Board, Settlement Bureau, for the inclusion of treasury function gross receipts in the taxpayers’ California sales factor.
Represents many of the largest financial sector companies (introducing and clearing broker-dealers, mutual fund complexes, banks, etc.) as well as insurance companies defending against industry-focused multistate unclaimed property examinations conducted by contract audit firms Verus, Kelmar, and the Unclaimed Property Clearinghouse (UPCH).
Co-authored an amicus brief filed with the U.S. Supreme Court that suggested grounds upon which the Court eventually disposed of a state tax discrimination challenge.
Assisted numerous clients with the defense of multistate unclaimed property audits conducted by third-party audit firms, and negotiated settlements with audit-participating states.
Obtained a favorable settlement for a client in litigation with the District of Columbia Office of Tax and Revenue over the proper apportionment methodology for a media/broadcasting company.
Represented a client in a transfer pricing audit by the New Jersey Division of Taxation that resulted in a highly favorable settlement.