Jeffrey S. Reed is the Chair of the State and Local Tax Practice. A former litigator for the Massachusetts Department of Revenue, Mr. Reed has represented clients in state tax controversy matters in over thirty states and has obtained favorable letter rulings for clients in several different jurisdictions. He regularly advises on the constitutionality of state tax positions, the availability of exemptions and incentives, and how to source revenue streams for state corporate income tax and sales tax purposes. He has handled New York qui tam (whistleblower) lawsuit litigation and received widespread acclaim for arguing and winning the closely-watched IT USA, Inc. case before the New York Tax Appeals Tribunal.
Besides state tax, Mr. Reed also devotes a significant part of his practice to unclaimed property. His unclaimed property experience includes representing holders in large multistate audits conducted by contingency fee audit firms as well as single-state audits of holders. He has experience with general ledger audits and audits of specific property types (for example, securities). He also provides unclaimed property guidance on issues including developing unclaimed property policies and procedures to mitigate audit risk, determining whether certain property is subject to reporting, and he negotiates voluntary disclosure agreements on behalf of clients.
In the federal tax area, Mr. Reed has favorably resolved IRS audits and has successfully represented taxpayers in appeals conferences before the IRS Office of Appeals.
Mr. Reed has written nearly thirty articles on state tax related issues and is the author of “The Reed Report,” a State Tax Notes column. He also writes a “Shop Talk” column for the Journal of Multistate Taxation and Incentives. He is the former Editor In Chief of the State and Local Tax Lawyer and is on the State and Local Tax Executive Committees for both the American Bar Association and the New York City Bar Association. His articles have been published in BNA Tax Management’s Multistate Tax Report, Corporate Counsel, Inside New York Taxes, Private Wealth, the Journal of Taxation and Regulation of Financial Institutions, E-Commerce Times, and Legal Times.
A regular lecturer on state and local tax matters, Mr. Reed has spoken before organizations such as BNA CITE, Bloomberg BNA, the Broadband Tax Institute, the Council on State Taxation (COST), the Tax Executives Institute (TEI), the Institute for Professionals in Taxation, Lorman Educational Seminars, and New York University’s Summer Institute in State and Local Taxation. He is a member of the New York University and Cornell University State and Local Tax lunch groups.
Mr. Reed began his state and local tax career at the Massachusetts Department of Revenue, where he litigated cases before the Appellate Tax Board and negotiated settlements with taxpayers. Prior to joining the firm, he worked for the state tax group of a prominent international law firm.
While attending college, Mr. Reed studied abroad for a year at Oxford University in Oxford, England.
Mr. Reed was recognized in 2017, 2018 and 2019 as a New York “Rising Star” for Tax Law by Super Lawyers magazine.
Obtained a favorable New York advisory opinion concluding taxpayer’s service is not subject to New York sales tax.
Represented taxpayer in several state audits stemming from the sale and liquidation of a business line.
Reviewed agreements for clients considering state tax credits and incentives.
Developed winning New Mexico Gross Receipts Tax audit position for service provider.
Advised taxpayer on the extent to which online services are subject to sales tax in various states.
Represented an online service company in a state audit asserting that the client’s service was subject to sales tax.
Resolved numerous significant New York corporate income tax and bank tax audits.
Represented taxpayer in Massachusetts research credit audit.
Argued and won the IT USA, Inc. case before the New York Tax Appeals Tribunal, resulting in complete cancellation of the assessment.
Assisted company relocating its headquarters in obtaining the best incentives package between several competing states.
Obtained a highly-favorable settlement for a luxury goods retailer in a New York sales tax case.
Obtained complete concession by New Hampshire for a proposed business profits tax assessment for an energy company.
Obtained voluntary disclosure agreements for several companies through the Multistate Tax Commission’s National Nexus Program.
Handled several qui tam whistleblower cases with the New York Attorney General’s Office.
Represented taxpayer in a Multistate Tax Commission audit, resolving several individual state tax assessments.
Represented buyer of transferable film credits and made revisions to purchase agreement.
Obtained a favorable Virginia income apportionment ruling for a financial institution.
Analyzed whether company was engaged in “manufacturing” for purposes of claiming state tax incentives.
Advised taxpayers on sales tax issues relating to purchases of aircraft, artwork, and other valuable assets.
Advised taxpayer on state withholding for deferred compensation and stock option payments.
Assisted in determining District of Columbia Qualified High Technology Company benefits eligibility.
Represented a business taxpayer and favorably resolved an Illinois unitary/non-unitary case.
Advised on the structuring of a partnership agreement between a sponsor and recipients of California solar energy credits.
Represented a financial institution in multi-state audits involving proposed assessment of additional corporate income tax based on an “economic nexus” theory.
Performed a nexus review for a technology company and obtained voluntary disclosure agreements in various states.
Drafted agreement for seller to transfer Brownfield Redevelopments credits.
Favorably resolved numerous state residency audits involving both domicile and statutory residency.
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Boston University School of Law, J.D.
New York University School of Law, LL.M.
Kenyon College, B.A.
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 Revised the Uniform Unclaimed Property Act
New York City Bar Association, State and Local Tax Section, Executive Committee Member
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