Bradley M. Seltzer

BS
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Attorney Awards

Biography

Brad Seltzer brings nearly 40 years of experience representing Fortune 100 utility, energy and telecom clients in complex tax matters, including tax planning, accounting and controversy. He defends clients in large tax disputes with the Internal Revenue Service (IRS) at both the trial and appellate court levels, and prepares private letter rulings, technical advice requests and accounting method changes for the IRS National Office.

Brad has extensive experience testifying at public hearings on behalf of clients regarding proposed regulations that affect the utility industry, such as interest synchronization, consolidated tax adjustments and the normalization consequences of dispositions or deregulation. He also counsels on tax saving strategies and manages complex tax refund claims, audits, appeals and litigation.

Brad is a frequent speaker on utility and telecom tax topics at various industry conferences and before various trade associations and professional organizations, including the American Bar Association Section of Taxation, the Edison Electric Institute, the American Gas Association, the National Association of Regulatory Utility Commissioners and the IRS.

Brad returns to Eversheds Sutherland (US) after nearly a 20-year stint with Deloitte Tax, where he most recently served as Global and U.S. Tax Leader of its Energy Resources and Carbon Markets groups.

Awards and Rankings

Recognized by The Legal 500 United States in the area of international tax (2017) and U.S taxes: contentious (2017)

Publications

Legal Alerts

Legal Alert: Proposed 163(j) regulations provide needed guidance to utilities (December 7, 2018)
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the ...

Legal Alert: House bill proposes tax credit extensions for renewable energy, biodiesel and alternative fuels and other energy tax provisions (November 30, 2018)
On November 26, the House of Representatives released a tax bill (Extenders Bill) that, if enacted, would extend certain tax credits for the renewable energy and alternative fuels industries and ...

Legal Alert: IRS tells utility not to count its (deferred tax) chickens before they hatch (October 24, 2018)
The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had ...

Legal Alert: What you need to know about investing in opportunity zones (October 24, 2018)
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities ...

Legal Alert: Proposed 168(k) regulations offer several surprises for utilities and present challenges with uncertainties left unaddressed (August 10, 2018)
The proposed regulations under section 168(k) issued by Treasury and the Internal Revenue Service (IRS) on August 3, 2018, not only presented utilities with some surprises, but also raised concerns ...

Legal Alert: The more things change the more things remain the same-temporary guidance regarding bonus depreciation rules under section 168(k) (August 8, 2018)
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many ...

Legal Alert: FERC orders natural gas pipelines to address federal income tax changes (July 24, 2018)
On July 18, the Federal Energy Regulatory Commission (FERC) issued orders (i) adopting procedures to implement the federal corporate income tax rate reduction in natural gas pipeline rates, and (ii) ...

Legal Alert: IRS rules that a method of reflecting a federal income tax settlement in ratemaking violated the consistency rule of normalization (July 17, 2018)
In PLR 201828010, the Internal Revenue Service (IRS) considered the proper ratemaking treatment for reflecting the results of a federal income tax settlement. The taxpayer was a member of an ...

Legal Alert: The long-awaited “solar beginning of construction notice”-Notice 2018-59 provides guidance for solar and other section 48 ITC-eligible facilities (June 27, 2018)
On June 22, 2018, the Internal Revenue Service (IRS) issued much-anticipated guidance to help developers of, and other industry participants in, solar, qualified fuel cell, qualified microturbine, ...

Legal Alert: IRS releases 2018 section 45 production tax credit amounts (June 25, 2018)
The Internal Revenue Service (IRS) recently published Revenue Procedure 2018-50, which provides the inflation-adjustment factors and reference prices to be used in the calculation of renewable energy ...

Articles

House Bill Proposes Tax Credit Extensions for Renewable Energy, Biodiesel and Alternative Fuels and Other Energy Tax Provisions (December 6, 2018)
Breaking Energy
On November 26, the House of Representatives released a tax bill (Extenders Bill) that, if enacted, would extend certain tax credits for the renewable energy and alternative fuels industries and ...

Unpacking The New Temporary Rules For Bonus Depreciation (September 12, 2018)
Law360
Last year, the federal government enacted the most substantial tax reform legislation since 1986, commonly referred to as the Tax Cuts and Jobs Act of 2017. Of the many business-friendly changes, the ...

A Federal Tax Perspective On Judge Kavanaugh (July 16, 2018)
Law360
Judge Brett Kavanaugh’s nomination to the US Supreme Court has prompted a collective deep dive into his nearly 300 opinions for the US Court of Appeals for the District of Columbia Circuit, in search ...

A Practical Method For Utility Property Interest Allocation (June 20, 2018)
Law360
Under Section 163(j) of the Internal Revenue Code, as amended by the recent tax reform bill, interest deductions are limited but certain exceptions are provided, including interest paid in the ...

Will Tax Reform Affect Utility Rates? (January 18, 2018)
Law360
Amidst the hyperbolic din emanating from politicians, reporters, analysts and others regarding the alleged massive refunds awaiting utility ratepayers (i.e., customers) following the federal ...

What Tax Reform Means For The Energy Sector: Part 2 (January 9, 2018)
Law360
On December 22, 2017, the President signed into law the bill informally referred to as the Tax Cuts and Jobs Act, which was passed by the US House of Representatives and Senate earlier in the week. ...

What Tax Reform Means For The Energy Sector: Part 1 (January 8, 2018)
Law360
On December 22, 2017, the President signed into law the bill informally referred to as the Tax Cuts and Jobs Act, which was passed by the US House of Representatives and Senate earlier in the week. ...

Newsletters

Eversheds Sutherland Global Tax Brief (December 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

News

In the News

Regulators Anticipate Legislative Changes to Bonus Depreciation (August 22, 2018)
Tax Notes
Eversheds Sutherland Partners Ellen McElroy and Bradley Seltzer are quoted in this Tax Notes article discussing the anticipated legislative changes to the proposed bonus depreciation regulations ...

Kavanaugh's Tax Opinions Offer Insight Into Role As Justice (July 10, 2018)
Law360
Eversheds Sutherland Partner Bradley Seltzer is quoted in this Law360 article providing insight on Judge Kavanaugh's writings on tax and what they reveal about the direction he might take as a ...

Federal Tax Cases To Watch In The 2nd Half Of 2018 (July 6, 2018)
Law360
Eversheds Sutherland Partner Bradley Seltzer is mentioned in this Law360 article discussing federal tax case Chamber of Commerce v. IRS.

Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor (March 2018)
Lexis Federal Tax Journal Quarterly
Eversheds Sutherland’s legal alert, Extending an Olive Branch: IRS Issues Ruling Providing Taxpayer Relief for Late Election of Rev. Proc. 2011-29 Safe Harbor, is featured in the March 2018 edition ...

Tax Court Provides Cover for Vulnerable Treasury Rules (January 30, 2018)
Law360
Eversheds Sutherland Partner Bradley Seltzer is quoted in this Law360 article regarding the US Tax Court rulings in Altera Corp. v. Commissioner and SIH Partners LLP v. Commissioner. Bradley said, ...

Tax Accounting Rules Restrict Utilities’ Ability to Reduce Rates (January 22, 2018)
Tax Notes
Eversheds Sutherland Partner Bradley Seltzer is quoted in this Tax Notes article regarding public utilities facing pressure to lower their customer rates in response to the new, lower corporate tax ...

Nuclear Industry Pushes IRS For Decommissioning Fund Rule Change (October 30, 2017)
Bloomberg BNA
Eversheds Sutherland Partner Bradley Seltzer is quoted in this Bloomberg BNA article discussing a simpler approach the Internal Revenue Service (IRS) could take to decommission power plants and clear ...

IRS Updates Accounting Method Change Procedures (May 9, 2017)
AccountingWEB
Eversheds Sutherland (US)’s legal alert, IRS Releases Updated Automatic Changes in Methods of Accounting List, is mentioned in this AccountingWEB article.

More Lateral Moves (June 27, 2016)
The Am Law Daily
Bradley Seltzer and Barry Stopler are mentioned in this article by The American Lawyer for joining Sutherland’s Tax Practice Group in Washington and New York, respectively. Bradley returns to ...

Movers - Bradley Seltzer (June 24, 2016)
The National Law Journal
Bradley Seltzer is mentioned in this National Law Journal article for joining the firm's Tax Practice Group as a partner in the Washington DC office. The article notes that Bradley will focus on ...

Press Releases

19 Eversheds Sutherland (US) Practice Areas, 58 Attorneys Named Among Nation’s Best in 2017 Legal 500 United States (May 31, 2017)
Eversheds Sutherland (US) LLP is pleased to announce that 19 practice areas and 58 attorneys have been ranked in the 2017 edition of The Legal 500 United States. Legal 500 is a comprehensive survey ...

Sutherland Bolsters Tax Practice with Addition of Partner Bradley Seltzer (June 1, 2016)
WASHINGTON-Sutherland Asbill & Brennan LLP announced today that Bradley M. Seltzer has joined the firm’s Tax Practice Group as a partner in the Washington DC office. Mr. Seltzer returns to Sutherland ...

Areas of Practice (9)

  • Tax
  • Federal Tax
  • Tax Controversy & Litigation
  • Technology, Media & Telecommunications Transactions
  • Natural Gas
  • Renewable & Alternative Energy
  • Risk, Regulatory & Compliance
  • Corporate Governance
  • Electric Utilities

Education & Credentials

Contact Information:
202.383.0808  Phone
www.eversheds-sutherland.com
University Attended:
State University of New York at Albany, B.A., magna cum laude
Law School Attended:
George Washington University Law School, J.D., with high honors
Year of First Admission:
1978
Admission:
U.S. Court of Appeals for the District of Columbia; U.S. Tax Court; U.S. Court of Federal Claims; District of Columbia; California; U.S. Supreme Court
Memberships:

Professional Activities

Former Chair, Section of Taxation, Section of Public Utility, American Bar Association
Former Chair, Section of Taxation, Normalization and Industry Specialization Subcommittees, American Bar Association
Former Member, Taxation Section, Steering Committee and Tax Policy Committee, District of Columbia Bar

Birth Information:
Massapequa, New York, September 26, 1953
ISLN:
903856728

Peer Reviews

5.0/5.0
A Martindale-Hubbell Peer Rating reflects a combination of achieving a Very High General Ethical Standards rating and a Legal Ability numerical rating.

*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (10)

Documents by this lawyer on Martindale.com

Washington, District of Columbia

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