Jeffrey A. Friedman

Jeffrey A. Friedman: Attorney with Eversheds Sutherland (US) LLP

Biography

Honored as “Tax Lawyer of the Year” in 2011 by State Tax Notes, Jeff Friedman provides sophisticated state and local tax planning, strategic advice and advocacy to numerous Fortune 100 and industry-leading companies. His comprehensive practice includes state and local tax planning, compliance, legislation and policy, and litigation and controversy matters involving income, franchise, sales and use and property taxes. Jeff’s clients span a variety of industries, including e-commerce, energy, technology and telecommunications.

A recognized thought leader on state and local tax issues, Jeff works on high-profile and precedent-setting litigation and controversy matters across the country. These matters impact critical questions on nexus, apportionment, the Multistate Tax Compact and the equal protection, due process and commerce clauses of the United States Constitution. Jeff is also a well-respected advocate on issues of tax policy, including the taxation of digital economy transactions.

Prior to joining Eversheds Sutherland (US), Jeff was a partner in KPMG’s Washington national tax practice; served as an attorney-adviser in the U.S. Department of the Treasury’s Office of Tax Policy, where he assisted with the development of the U.S. government's position on domestic and international electronic commerce tax issues; and served as vice president and counsel of the Committee (now Council) On State Taxation (COST).

Selected Experience

Won a refund of more than $10 million for GenOn Mid-Atlantic in a constitutional challenge to Montgomery County, Maryland's excise tax specifically targeting GenOn.
Advises leading online retailer about state tax issues.
Saved Fortune 100 tech firm $70 million in potential Washington State sales tax liability.

Publications

“One of the most pressing issues facing businesses today is the taxation of digital economy transactions. The state tax ramifications of cloud computing, digital goods and services, electronic payments, and other goods and services delivered or transferred electronically are incomplete, ambiguous and evolving.”

Legal Alerts

Legal Alert: Maryland bill proposes digital goods tax (February 4, 2019)
The Maryland House of Delegates is considering legislation (House Bill 426) that would impose sales and use tax on digital products and sales tax on digital codes. If signed into law, Maryland would ...

Legal Alert: Missouri bill would require payment processors to collect sales tax (January 25, 2019)
The Missouri House of Representatives is considering legislation (House Bill 648) that would impose sales tax collection obligations on payment processors.1 House Bill 648 was introduced on January ...

Legal Alert: New York Governor proposes significant tax changes (January 17, 2019)
New York State Governor Andrew Cuomo released his Fiscal Year 2020 budget and accompanying legislation on January 15, 2019 (the Budget Bill). Among other things, the Budget Bill proposes statutory ...

Legal Alert: New York instructs taxpayers on GILTI apportionment (January 14, 2019)
The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as ...

Legal Alert: DC QHTC regulation amended to require new application procedure (January 8, 2019)
Background The District provides a variety of tax benefits to QHTCs, including sales and use tax1 and personal property tax exemptions,2 as well as a reduced corporation franchise tax rate.3 In ...

Legal Alert: District of Columbia imposes Wayfair nexus standard, digital goods taxation and marketplace sales tax collection requirements (January 3, 2019)
On December 31, 2018, District of Columbia Mayor Muriel Bowser signed B22-1070, the Internet Sales Tax Emergency Amendment Act of 2018 (Emergency Act). As of January 1, 2019, the District of Columbia ...

Legal Alert: It’s Not the Eggnog - New Jersey Proposes to Specially Allocate GILTI Based on GDP (December 24, 2018)
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible ...

Legal Alert: Consolidated complexities - state corporate income tax implications of I.R.C. 163(j) (December 18, 2018)
In a year that has seen sweeping changes to the state tax landscape brought about by the Tax Cuts and Jobs Act’s (TCJA) revisions to the Internal Revenue Code (I.R.C. or Code), the majority of state ...

Legal Alert: Thanksgiving dinner arrives early - New Jersey serves up some amnesty dessert with some penalty turkey (November 15, 2018)
New Jersey launched its tax Amnesty program on November 15, 2018. The program runs through January 15, 2019. Here are the top things you need to know about the program:What taxes qualify? All ...

Legal Alert: Results are in - state tax ballot measures (November 8, 2018)
The dust is beginning to settle from the 2018 midterm elections. Though the nation has been focused this week on the federal House and Senate races, several state ballot measures have significant ...

Articles

The Votes Are In: State Responses to Federal Tax Reform (December 3, 2018)
Tax Executive
H.R. 1, colloquially known by its former name, the Tax Cuts and Jobs Act (TCJA), made sweeping changes to the Internal Revenue Code and has far-reaching implications for state tax systems that ...

Non-tax lawyer’s guide to the Tax Cuts and Jobs Act (Summer 2018)
Partnering Perspectives
On December 22, 2017, the largest overhaul of the nation’s tax code since 1986 was signed into law. While the reduction in the corporate income tax rate grabbed most of the headlines, in their ...

State Tax After TCJA: Treatment Of International Income (May 8, 2018)
Law360
The Tax Cuts and Jobs Act, P.L. 115-97,[1] made sweeping changes to the Internal Revenue Code, and will have far-reaching implications for state tax systems that broadly conform to the IRC. In this ...

A Pinch of SALT: Implications of the MTC's Market-Based Sourcing Model Regulations (March 26, 2018)
State Tax Notes
It is more complicated to determine an in-state sale regarding the provision of multistate services or licenses of intangibles. Historically, states looked to a taxpayer’s costs of performing the ...

Waiting for the Other Shoe to Drop: State and Local Tax Implications of Federal Tax Reform - International Tax Provisions (March 12, 2018)
Bloomberg Tax - Daily Tax Report: State
The state and local tax (SALT) impact of the recently enacted federal tax reform is still being assessed. Because of states’ broad conformity to the federal income tax laws, many of these changes ...

A Pinch of SALT: Maryland’s Alternative Apportionment Violates Internal Consistency (January 1, 2018)
State Tax Notes
In this edition of A Pinch of SALT, Eversheds Sutherland attorneys Jeffrey Friedman, Timothy Gustafson and DeAndre Morrow discuss the Maryland comptroller’s use of alternative apportionment for ...

The Most Important State And Local Tax Cases Of 2017 (December 21, 2017)
Law360
There has been no shortage of state tax controversies this year. States and taxpayers looked to state courts seeking guidance on some of the most contentious state tax issues. In their article for ...

Pennsylvania NOL Cap Ruling Presents Taxpayer Challenges (November 15, 2017)
Law360
The Pennsylvania Supreme Court held that the state’s flat $3 million cap on net operating loss (NOL) carryforwards violates the state constitution’s uniformity clause. While the court’s reasoning is ...

Developing Strategic Solutions to Multistate Tax Litigation (May 1, 2017)
State Tax Notes
In their article for State Tax Notes, Eversheds Sutherland (US) attorneys Jeffrey Friedman and Stephanie Do along with Pilar Mata, Tax Counsel at Tax Executives Institute, discuss the complexities of ...

Ohio Tax Litigation Reflects Evolving Nexus Landscape (May 6, 2016)
Law360
The Ohio Supreme Court recently heard oral arguments in three cases that could test the constitutionality of the Ohio commercial activity tax (CAT). These cases turn on whether the CAT’s ...

Newsletters

Eversheds Sutherland SALT Scoreboard (Quarter 4, 2018)
This is the twelfth edition of the Eversheds Sutherland SALT Scoreboard, and the last edition from 2018. Since 2016, Eversheds Sutherland has tallied the results of what we deem to be significant ...

Eversheds Sutherland SALT Scoreboard (Quarter 3, 2018)
This is the eleventh edition of the Eversheds Sutherland SALT Scoreboard, and the third edition of 2018. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses ...

Eversheds Sutherland SALT Scoreboard (Quarter 2, 2018)
This is the tenth edition of the Eversheds Sutherland SALT Scoreboard, and the second edition of 2018. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses ...

Partnering Perspectives: Insights from Inside and Outside the Corporate Law Department (Summer 2018)
We are pleased to present the Summer 2018 edition of Partnering Perspectives, which focuses on a number of developing legal issues as well as offers insight on the value to clients of partnering with ...

Eversheds Sutherland SALT Scoreboard (Quarter 1, 2018)
This is the ninth edition of the Eversheds Sutherland SALT Scoreboard, and the first of 2018. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses and analyze ...

Eversheds Sutherland SALT Scoreboard (Quarter 4, 2017)
This is the fourth quarter and year-end wrap-up of the 2017 Eversheds Sutherland SALT Scoreboard. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses and ...

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 ...

Eversheds Sutherland SALT Scoreboard (Quarter 3, 2017)
This is the seventh edition of the Eversheds Sutherland SALT Scoreboard. Each quarter, we tally the results of what we deem to be significant taxpayer wins and losses and analyze those results. This ...

Eversheds Sutherland Global Tax Brief (October 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 ...

Eversheds Sutherland Global Tax Brief (July 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 ...

Presentations

“It is time to move away from historical categories based on outmoded concepts such as canned versus custom software. At the same time, we must be cautious because while nonsensical results can arise from trying to force transactions into outmoded categories, the development of more relevant definitions can lead to transactions being double-taxed.”

Presentations

Federal and State Controversy Update (April 17, 2019)
TEI Seattle Chapter Meeting
Eversheds Sutherland (US) Partners Jeffrey Friedman, Michele Borens and Daniel R.B. Nicholas present Federal and State Controversy Update at the TEI Seattle Chapter Meeting on April 17, 2019, in ...

Panel on Living in the Digital World - Taxing the Digital Economy (April 3, 2019)
2019 TEI Mid-Year
Eversheds Sutherland (US) Partner Jeffrey Friedman presents Panel on Living in the Digital World - Taxing the Digital Economy at the 2019 TEI Mid-Year on April 3, 2019, in Washington, DC.

Slicing and Serving the Pie: State Filing and Apportionment Methods - No Seconds (February 22, 2019)
UW-TEI Tax Forum
Eversheds Sutherland (US) Partners Jeffrey Friedman and Michele Borens present Slicing and Serving the Pie: State Filing and Apportionment Methods - No Seconds at the UW-TEI Tax Forum ...

National Multistate Tax Symposium (February 8, 2019)
Eversheds Sutherland Partner Jeffrey Friedman presents State Tax Consequences of International Restructurings and Eversheds Sutherland Partner Todd Lard presents State Tax Policy: Recent ...

Federal Tax Reform Update (December 6, 2018)
Council on State Taxation (COST)
Eversheds Sutherland (US) Partner Jeff Friedman presents Federal Tax Reform Update at the COST Regional Meeting on December 6, 2018, in Seattle, Washington.

Marketplace Collection - The Ins, Outs, and Next Chapter (December 6, 2018)
Council on State Taxation (COST)
Eversheds Sutherland (US) Partners Michelle Borens and Jeff Friedman present Marketplace Collection - The Ins, Outs, and Next Chapter at the COST Regional Meeting on December 6, 2018, in Seattle, ...

73rd Annual Conference (October 23 - 25, 2017)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) is a proud sponsor of the 2018 TEI Annual Conference on October 29-31, 2018, in San Diego, California. (US) Partner Jeff Friedman presents, “State Implications of Federal ...

49th Annual Meeting (October 23-26, 2018)
Council on State Taxation (COST)
Eversheds Sutherland (US) is a proud sponsor of the COST Annual Meeting on October 23-26, 2018, in Phoenix, Arizona. The Eversheds Sutherland SALT Team presents, and details of their presentations ...

State and Local Tax Forum (October 17-19, 2018)
Paul J. Hartman
Eversheds Sutherland (US) is a proud sponsor of the Paul J. Hartman State and Local Tax Forum on October 17-19, 2018, in Nashville, Tennessee. (US) Partner Jeff Friedman presents, “Federal Tax Reform ...

State Tax Developments related to the Federal Tax Reform (September 20, 2018)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) Partner Jeff Friedman presents, “State Tax Developments Related to the Federal Tax Reform,” at the TEI Cleveland Chapter Meeting on September 20, 2018, in Independence, Ohio.

News

In the News

Post-Wayfair Due Process Nexus Questions Reach Supreme Court (January 28, 2019)
Tax Notes
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Tax Notes article discussing questions that have risen from recent court decisions pertaining to nexus under the commerce clause and ...

State and Local Tax Policy to Watch In 2019 (January 1, 2019)
Law360
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Law360 article discussing state and local tax policy predictions for 2019. Jeff said, “We could see more state tax legislation and ...

States Need to Expect the Unexpected as TCJA Fallout Continues (October 22, 2018)
Tax Notes
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Tax Notes article regarding the Tax Cuts and Jobs Act’s domestic and international provisions, and the uncertainty the provisions have ...

Major Issues in a Post-Wayfair World (July 31, 2018)
Accounting Today and TaxPro Today
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Accounting Today article discussing the issues companies are facing post Wayfair. Jeff said reactions to the decision have gone one or ...

New Tax Burdens on App, Software Sellers After 'Wayfair' (July 9, 2018)
Bloomberg BNA - Daily Tax Report
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Bloomberg BNA article discussing the compliance challenges smaller developers and retailers will face now that the US Supreme Court has ...

Battle Over State Income Tax Nexus Lurks in Post-Wayfair Era (June 28, 2018)
Law360
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Law360 article discussing the Supreme Court’s ruling on South Dakota v Wayfair and what it means for the physical presence standard in ...

Sales Tax Decision Looms Large in Justice Kennedy's Legacy (June 28, 2018)
Law360
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Law360 article discussing the announcement of Supreme Court Justice Anthony Kennedy’s retirement and the impact of his recent opinion ...

Could High Court Sales Tax Ruling Be Boon to Class-Action Lawyers? (May 23, 2018)
Bloomberg Law
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Bloomberg Law article discussing the possible affect the Supreme Court ruling on South Dakota v. Wayfair, Inc. could have on fending ...

The Morning After: More Reaction to Oral Argument in Wayfair (April 19, 2018)
Tax Notes
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Tax Notes article discussing recent oral arguments in the Supreme Court case South Dakota v. Wayfair Inc. Jeff said he was surprised ...

South Dakota Rebuffs E-retailer Concerns in Last High Court Brief (April 9, 2018)
Bloomberg BNA
Eversheds Sutherland Partner Jeffrey Friedman is quoted in this Bloomberg BNA article regarding Supreme Court case South Dakota v Wayfair and South Dakota’s claim that safeguards are in place ...

Press Releases

18 Eversheds Sutherland Practice Areas, 68 Attorneys Named Among Nation’s Best in 2018 Legal 500 United States (May 30, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 18 practice areas and 68 attorneys have been recognized in the 2018 edition of The Legal 500 United States, a comprehensive survey of legal ...

19 Eversheds Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2018 Chambers USA (May 3, 2018)
Eversheds Sutherland (US) LLP is pleased to announce that 19 practices and 59 attorneys have earned recognition in the 2018 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers ...

16 Eversheds Sutherland (US) Attorneys Named 2018 Washington DC Super Lawyers and Rising Stars (April 23, 2018)
WASHINGTON-Eversheds Sutherland (US) LLP is pleased to announce that 10 of its attorneys based in Washington DC have been selected as top attorneys in the District of Columbia by Super Lawyers . ...

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 ...

20 Eversheds Sutherland (US) LLP Practice Areas, 56 Attorneys Named Among Nation’s Best in 2017 Chambers USA (May 26, 2017)
Eversheds Sutherland (US) LLP is pleased to announce that 20 practices and 56 attorneys at the firm earned recognition in the 2017 edition of Chambers USA: America’s Leading Lawyers for Business. ...

17 Eversheds Sutherland (US) Attorneys Named 2017 Washington DC Super Lawyers and Rising Stars (April 25, 2017)
WASHINGTON-Eversheds Sutherland (US) LLP is pleased to announce that 10 of the firm’s attorneys based in Washington DC have been selected as top attorneys in the District of Columbia by Super ...

16 Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2016 Legal 500 United States (June 16, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 16 practice areas and 59 attorneys have been ranked in the 2016 edition of The Legal 500 United States. Legal 500 is ...

21 Eversheds Sutherland (US) LLP Practice Areas, 56 Attorneys Named Among Nation’s Best in 2016 Chambers USA (May 27, 2016)
Eversheds Sutherland (US) LLP announces that 21 practices and 56 attorneys at the firm earned recognition in the 2016 edition of Chambers USA: America’s Leading Lawyers for Business. Chambers USA, a ...

20 Sutherland Attorneys Named 2016 Washington DC Super Lawyers and Rising Stars (April 21, 2016)
WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 13 of the firm’s attorneys based in Washington DC have been selected as top attorneys in the District of Columbia by Super ...

Sutherland SALT Launches “SALT Scoreboard” Publication (April 7, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that the firm’s State and Local Tax (SALT) practice has launched the “SALT Scoreboard,” a quarterly publication that ...

Awards and Rankings

“At Eversheds Sutherland (US), we work as a team-sharing information, bringing the right lawyers to the right projects and collaborating to best support each other and our clients.”

Recognized by Law360 as Tax MVP of the Year (2014)

State Tax Notes “Tax Lawyer of the Year” (2011)

Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2012-2018)

Recognized by The Legal 500 United States in the areas of tax (2012, 2015); U.S. taxes: contentious (2011-2012, 2015, 2018); U.S. taxes: non-contentious (2016, 2018); and international tax (2017-2018)

Named among the elite “Leading Lawyers” list by Legal 500 United States in the area of U.S. taxes: non-contentious(2018)

State Tax Notes “People to Watch” (January 2010)

Recommended by PLC Which Lawyer? in the area of tax (2008-2012)

Selected for inclusion in Washington, DC, Super Lawyers (2014-2018)

Areas of Practice (9)

  • Tax
  • State and Local Tax
  • Tax Controversy & Litigation
  • Appellate
  • Insurance
  • Unclaimed Insurance Benefits
  • Digital Economy
  • Technology
  • Media & Telecommunications Transactions

Education & Credentials

Contact Information:
202.383.0718  Phone
www.eversheds-sutherland.com
University Attended:
University of Maryland, B.S.
Law School Attended:
University of Maryland School of Law, Managing Editor, The Business Lawyer, J.D., with high honors; Georgetown University Law Center, LL.M., with distinction
Year of First Admission:
1995
Admission:
1995, Maryland; 2004, District of Columbia
Memberships:

Professional Activities

Adjunct Professor, New York University School of Law
Faculty Member, Council On State Taxation Income Tax School
Faculty Member, Tax Executives Institute's State and Local Tax School

Birth Information:
Newark, New Jersey, June 7, 1967
ISLN:
912251668

Peer Reviews

This lawyer does not have peer reviews.

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

Documents (115)

Documents by this lawyer on Martindale.com

Washington, District of Columbia

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