With an extensive tax practice, Jeffrey represents a broad client base of Fortune 500, midsized and smaller companies. His practice encompasses federal and international tax issues, including advice on structuring complex international and cross-border transactions, Internal Revenue Code (IRC) Section 482 transfer pricing matters and representation in national and international tax disputes, such as audit management, administrative appeals and litigation in U.S. courts. Jeffrey also has extensive experience providing advice on technical tax issues and compliance, including uncertain tax positions, withholding tax, information returns, excise tax issues and state and local tax.
Civic Involvement
ˇ Olympia Fields Country Club, President, 2010-2012
Experience
ˇ Represented large multinational company in connection with split-off transaction and cross-border financing arrangements, existence of true debt for tax purposes, withholding tax and compliance
ˇ Represented multinational pharmaceutical company in connection with establishment of captive insurer, compliance, and in audit and administrative appeals
ˇ Advised insurer in acquisition and later dispute regarding tax-sharing agreement
ˇ Represented pharmacy benefit manager in connection with acquisition and in Internal Revenue Service (IRS) audit and administrative appeal regarding timing of deductions and other issues, as well as in connection with compliance and uncertain tax position filings
ˇ Counseled insurer in IRS audit and administrative appeal regarding adjustment in excess of $50 billion. Issues included valuation of insurance contracts and proper calculation of tax reserves
ˇ Represented Fortune 100 manufacturing entity in administrative appeal regarding $400 million adjustment relating to valuation of intellectual property
ˇ Advised Fortune 100 food and beverage entity in administrative appeal of large IRC Section 482 adjustment involving application of U.S. Treasury Department regulations on intangible property, IRC Section 6662 documentation requirements, and related matters
ˇ Successfully litigated case involving cross-border acquisition, IRC Section 357 "basis bump," and application of economic substance, substance over form and step transaction doctrines. Flextronics America v. United States
ˇ Successfully litigated case involving cross-border insurance arrangements, IRC Section 482 transfer pricing issues, and application of economic substance and substance over form doctrines. United Parcel Service of America v. United States
ˇ Successful representation of multinational communications entity in two-week arbitration hearing involving enforcement of tax-sharing agreement and reimbursement for Peruvian tax liabilities
News & Publications
News
4.16.12, Mayer Brown Attorney Joins Husch Blackwell's Tax Team
Publications
4.30.12, Whistleblower Suits Seek to Collect Sales Tax on Delivery Charges for Internet Sales