Karl Zeswitz, a member of Sutherland's Tax Practice Group, advises clients on a wide range of transactional tax planning and tax controversy matters. His practice is broad-based, involving all aspects of corporate and partnership tax planning for domestic and multi-national companies, publicly traded and privately held clients, and clients in the nonprofit sector. He also assists clients with tax accounting matters, FIN 48 reporting, worker classification issues, financing transactions and consolidated return issues. His transactional practice focuses on tax planning in mergers, acquisitions, reorganizations and recapitalizations for domestic and cross-border transactions. He also advises clients in matters involving corporate joint ventures, venture capital and hedge funds, and complex pooling and financing arrangements. In addition to transactional tax planning, Karl maintains a significant tax controversy practice, handling individual and large case audits, and litigation in various federal and state jurisdictions. He has extensive experience in tax controversy matters at all administrative government levels (federal, state and local), including before the Internal Revenue Service (IRS) and U.S. Departments of the Treasury and Justice. He has litigated cases in federal jurisdictions, before the U.S. Tax Court, the U.S. Court of Federal Claims, the U.S. Court of Appeals for the Fifth, Sixth and Federal Circuits, as well as in trial and appellate courts in state and local jurisdictions, including in California, New York, Maryland, Virginia, Illinois and in the District of Columbia. State and local tax matters he has handled include income, franchise, sales and use, and business license tax controversies. Prior to joining Sutherland, Karl was the Washington, D.C., Tax Group Coordinator for a large national law firm (with that firm from 1986 to 1998). Before entering private practice, he was a Senior Trial Attorney with the Office of Chief Counsel (with the IRS from 1980 to 1985), where he was first chair in major tax litigation and served as senior counsel on other matters in the District Counsel office, including evaluation of criminal tax cases and bankruptcy proceedings. Karl's client base ranges from high-profile individuals in the entertainment industry to Fortune 50 businesses. He provides advice to CFOs and tax directors, as well as to major accounting firms and investment banks, with respect to domestic and international tax planning for businesses with global operations. He also frequently manages tax controversies that have adversarial as well as public relations challenges for clients well-known in the public domain. Additionally, Karl devotes time to teaching tax law, having served as an adjunct professor in the areas of taxation of partnerships, corporate tax, consolidated returns and income tax accounting in the LL.M. in Taxation program at Georgetown University Law Center for more than 20 years. Representative Experience Karl's extensive representative experience includes: · Advising Fortune 50 clients on corporate joint ventures including cross-border alliances. · Advising multi-national clients on structuring of global investment and acquisition opportunities. · Advising trade associations in merger and acquisition transactions. · Structuring equity and debt investment pools for clients in the insurance and investment banking industries. · Forming venture capital and hedge funds, and advising clients, including foreign investors and pension funds, with respect to private equity investments. · Advising and providing opinions to major accounting firms on application of partnership tax principles. · Representing clients in identifying and securing IRS consent to tax accounting method changes. · Advising clients in public-private partnership ventures, both in the nonprofit and government arenas. · Handling sensitive controversies with federal and state tax authorities on behalf of clients in the entertainment industry. · Handling worker classification controversies for prominent clients. · Managing and litigating federal tax cases on behalf of clients in the energy, consumer products and retail sectors. · Litigating state and local tax cases for clients in the commercial airline, restaurant and hotel industries. Professional and Community Involvement · Member, Tax Section, American Bar Association · Member, Tax Section, District of Columbia Bar · Member, Tax Section, Louisiana State Bar Association · Member, Tax Section, State Bar of California Recent Publications and Speaking Engagements · Co-author, "A Gambit Vanquished: The Rise and Fall of the 'Killer B,'" 52 Tax Management Memorandum 419 (2011) · Co-author, "Almost a 'Fall Classic': Proposed Treasury Regulations Leave a 'Series' of Issues Unresolved," 40 Tax Management International Journal 131 (2011) and 52 Tax Management Memorandum 75 (2011) · Co-author, "'Check-the-Box' Classification of Series Entities," DailyTax Report (January 22, 2009) · Author, "Classification of Series Entities," 49 Tax Management Memorandum 531 (2008) · Author, "Planning with Partnerships," Tax Executives Institute (TEI) Baltimore/Washington Chapter Annual Seminar, Reston, Virginia (2008) · Author, "Nukes Ride Again," 42 Energy (Winter 2006) · Author, "Primer on Partnership Issues," TEI Portland Chapter (2003) · Author, "State Taxation of Overflights" (1998) · Author, "The Developing Relationship Between U.S. Customs and the Internal Revenue Service," Customs Record (1994) · Speaker, "Tax Reform Proposals and the Upcoming Regulatory Agenda," Sutherland Tax Series: Session II (December 6, 2011) · Speaker, "Partnership Tax," TEI New Orleans Chapter Meeting (November 18, 2011) · Speaker, "A Gambit Vanquished: The Rise and Fall of the Killer B," BNA Tax Management U.S. International and Transfer Pricing Advisory Boards (August 18, 2011) · Speaker, "What's New in DC," TEI New Orleans Chapter Meeting (May 17, 2011) · Speaker, "Partnerships, LLCs, and LLPs: Uniform Acts, Taxation, Drafting, Securities, and Bankruptcy," ALI-ABA 34th Annual Advance Course of Study: Partnerships, LLCs and LLPs, Chicago, Illinois (2009) · Speaker, "The President-Elect's Tax Plan: Likelihood of Adoption and Possible Impact on Individuals and Corporate America," Tax Education Series VI, Georgia Tech Global Learning Center, Atlanta, Georgia (2008) · Speaker, "Classification of Series Entities," BNA Tax Management Advisory Board, New York (2008) · Speaker, "Partnership Liabilities, Nonrecourse Deductions and Section 704(c)," ALI-ABA 33rd Annual Advance Course of Study: Partnerships, LLCs and LLPs, San Francisco, California (2008) · Speaker, "Planning with Partnerships," TEI Region II Tax Forum, Atlantic City, New Jersey (2008) · Speaker, "Allocation of Partnership Income, Gains, Losses, and Liabilities," ALI-ABA 32nd Annual Advance Course of Study: Partnerships, LLCs and LLPs, Baltimore, Maryland (2007) · Speaker, "Recent Developments in Subchapter C," TEI Denver Chapter (2006) · Speaker, "The Tax Aspects of Foreign Corporations Doing Business in the U.S.," China IT Summit, New York (2006) · Speaker, "An Introduction to Structured Trust Acquisition Companies" (2006) · Speaker, "Allocation of Partnership Income, Gains, Losses, and Liabilities," ALI-ABA 31st Annual Advance Course of Study: Partnerships, LLCs and LLPs, Scottsdale, Arizona (2006) · Speaker, "Issues in Partnerships, Joint Ventures and LLCs," TEI Federal Tax Seminar, Scottsdale, Arizona (2006) · Speaker, "Partnerships and Joint Ventures," Atlanta, Georgia (2005) · Speaker, "Partnerships and Joint Ventures: Mergers and Acquisitions Issues," TEI Region III Annual Conference, Mashantucket, Connecticut (2005) · Speaker, "Allocation of Partnership Liabilities and Nonrecourse Deductions," ALI-ABA Partnerships, LLCs and LLPs (2000-2005) · Speaker, "Joint Ventures and Partnerships-Domestic and International," Cincinnati, Ohio (2004) · Speaker, "Recent Tax Cases," TEI New Orleans Chapter, New Orleans, Louisiana (2004) · Speaker, "Partnerships and Joint Ventures," TEI Region III, Harrisburg Chapter, Harrisburg, Pennsylvania (2003) · Speaker, "Choice of Entity Considerations," Federal Bar Association Insurance Tax Seminar, Washington, D.C. (2001) · Speaker, "Select Tax Accounting Issues-Building & Operating A Nuclear Power Plant" (2001) · Speaker, "Litigating the Inclusion of Bridge Miles," Air Transport Association, Albuquerque, New Mexico (1994) News Sutherland Tax Attorneys Review the Rise and Fall of "Killer B" Transactions
October 10, 2011 Sutherland Represents Tyco Electronics in its Acquisition of ADC
July 14, 2010 Sutherland Launches WorkerClassification.com
Web Site Addressing the Classification of Today's Workforce.
April 28, 2009 Sutherland Represents Tyco Electronics Ltd. in $675 Million Sale of Its Wireless Systems Business to Harris Corporation
April 28, 2009 Legal Alerts Legal Alert: New Worker Classification Procedures Affect IRS/DOL Compliance and Enforcement Efforts
September 26, 2011 Legal Alert: Many Happy (Consolidated) Returns or 'Til "DIT" Do Us Part? Final Treasury Regulations Address Intercompany Items of Gain on Member Stock
March 4, 2011 Legal Alert: Much Anticipated Guidance Concerning the Federal Tax Classification of Series Issued
September 15, 2010 Legal Alert: "Extenders" Legislation to Change the Taxation of Carried Interests
December 9, 2009 Legal Alert: Refunds of Federal Communications Excise Tax
April 19, 2006 Legal Alert: Congress Supports the Nuclear Power Renaissance
August 23, 2005 Publications A Gambit Vanquished: The Rise and Fall of the "Killer B"
October 2011 Reproduced with permission from Tax Management Memorandum Almost a "Fall Classic": Proposed Treasury Regulations Leave a "Series" of Issues Unresolved
2011 Reproduced with permission from Tax Management International Journal Almost a "Fall Classic": Proposed Treasury Regulations Leave a "Series" of Issues Unresolved
2011 Reproduced with permission from Tax Management Memorandum 'Check-the-Box' Classification of Series Entities
January 22, 2009 Reprinted with permission DailyTax Report , a publication of BNA, Inc. Nukes Ride Again
Winter 2006 Reprinted with permission, Energy "The Developing Relationship Between U.S. Customs and the Internal Revenue Service"
1994 Events Sutherland Tax Series: Session II
December 6, 2011 BNA Advisory Board Meeting
August 18, 2011 ALI-ABA Partnerships, LLCs, and LLPs: Uniform Acts, Taxation, Drafting, Securities, and Bankruptcy
July 16-18, 2009 Tax Education Series VI
2008 BNA Tax Management Advisory Board
2008 ALI-ABA 33rd Annual Advance Course of Study: Partnerships, LLCs and LLPs
2008 TEI Region II Tax Forum
2008 2006 China IT Summit
November 2-3, 2006 ALI-ABA 31st Annual Advance Course of Study: Partnerships, LLCs and LLPs
2006 An Introduction to Structured Trust Acquisition Companies
2006 TEI Denver Chapter
2006 TEI Federal Tax Seminar
2006 Partnerships and Joint Ventures
2005 ALI-ABA Partnerships, LLCs and LLPs
2000-2005 Partnerships and Joint Ventures: Mergers and Acquisitions Issues
2005 Joint Ventures and Partnerships-Domestic and International
2004 TEI New Orleans Chapter
2004 TEI Region III, Harrisburg Chaper
2003 Federal Bar Association Insurance Tax Seminar
2001 Select Tax Accounting Issues-Building & Operating A Nuclear Power Plant
2001 Air Transport Association
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