Overview

Jeff Reed chairs Kilpatrick Townsend’s State and Local Tax Practice. Jeff helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the United States.

Drawing on his experience as a former litigator for the Massachusetts Department of Revenue, Jeff brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. Jeff is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.

A prolific writer, Jeff’s articles on tax topics have been published in the leading industry journals, including Law360, Tax Notes State, Bloomberg/BNA and the Journal of Multistate Taxation and Incentives. Jeff serves on Law360’s Tax Editorial Advisory Board, and also on the Editorial Board for the Journal of Multistate Taxation and Incentives. He is a columnist for both Tax Notes State, and the Journal of Multistate Taxation and Incentives. He sits on the Executive Committee of the American Bar Association’s State and Local Tax Section, and on the Executive Committee for the New York City Bar Association.

Jeff regularly speaks before industry groups and organizations concerning substantive tax issues, and also issues relating to tax administration, practice, and procedure.

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Experience

Argued and won Matter of IT USA, a leading case addressing the standards for combination in New York, before the New York Tax Appeals Tribunal. Also won the same case before the New York Division of Tax Appeals.

Obtained TSB-A-15(20)S, a New York advisory opinion ruling that a company’s online drop-shipment hub service was not subject to New York sales and use tax.

Obtained a no-change letter in a New York sales/use tax audit for an online services provider.

Obtained a no-change letter in a New York residency audit for a well-known individual that owned a valuable property in New York City.

Obtained a tax refund for an out-of-state manufacturer in a composite return income tax case that had been pending at the Georgia Tax Tribunal.

Obtained a tax refund for an out-of-state manufacturer in a case that had been pending at the Massachusetts Appellate Tax Board.

Obtained voluntary disclosure agreements throughout the United States for a financial services company that had been filing income tax returns only in jurisdictions in which it had a physical presence.

Represented a pharmaceutical company in multi-state tax audits and appeals relating to tax base and apportionment issues following its sale and complete liquidation of a business line.

Counseled the owners of a cloud computing product with respect to evaluating sales tax exposure for sales of the product made to customers throughout the United States.

Defended a Fortune 500 company in a New York Qui Tam (whistleblower) investigation relating to a tax position taken by a subsidiary it had acquired.

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Education

Boston University School of Law, J.D.

New York University School of Law, LL.M.

Kenyon College, B.A.

Admissions

New York

Massachusetts

Professional & Community Activities

American Bar Association, SALT Publications Subcommittee, Chair

American Bar Association, State and Local Tax Section, Executive Committee, Member

American Bar Association, Unclaimed Property Subcommittee, Member of the Project to Revise the Uniform Unclaimed Property Act

New York City Bar Association, State and Local Tax Section, Executive Committee Member

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