mjacobs@reedsmith.com

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Michael's practice runs the gamut from state corporate income tax assessment appeals and refund claims to state tax planning in connection with business transactions. Michael has represented dozens of clients in the administrative and judicial appeals of state income tax issues, with particular experience in Pennsylvania, Massachusetts, Michigan, Texas and Virginia. Many of these appeals have resulted in multi-million dollar refunds or assessment reductions. Michael also advises public and private clients with respect to state and local sales and real estate transfer tax issues in connection with acquisitions and divestitures throughout the U.S. and counsels clients on their financial accounting provisions for state taxes.

Notable Quotes

  • 2 August 2017 "Wholesaler Liable for Tax in Massachusetts Drop Shipment Case" Tax Notes
  • 31 July 2017 "Massachusetts DOR Proposes Remote Sales Tax Collection Reg" Tax Notes
  • 27 June 2017 "Massachusetts DOR Updates Tax Return Guidance for Non-U.S. Corporations" Tax Notes
  • 10 April 2017 "Scope of Mass. Sales Tax Rule May Go Beyond Online Sales" Law360
  • 8 November 2016 "Massachusetts DOR Releases Updated Field Audit Manual" Tax Analysts
  • 5 November 2016 "Disproportionate Tax on Telecom Property Is Constitutional, Massachusetts High Court Holds" Tax Analysts
  • 3 November 2016 "Virginia Supreme Court Will Hear Case on Addback Exemption" Tax Analysts
  • 25 August 2016 "Maryland Tax Court Strikes Down State's Treatment of Federal Bond Interest" Tax Notes
  • 18 August 2016 “Refunds Possible After Massachusetts Loan Securitizer Case" Bloomberg BNA
  • 16 August 2016 “Bad News For Loan Co. Spells Refund Opportunity for Others” Law360
  • 15 August 2016 “Securitized Loan Interests Properly Assigned to Massachusetts, High Court Holds” Tax Analysts
  • 7 April 2016 "Massachusetts Tax Board Upholds Sales Tax on Distributor's Drop Shipments" Tax Analysts
  • 4 March 2016 "Pennsylvania Add-back Guidance Exceeds Statue, Critics Say; More Regulation Coming" Bloomberg BNA
  • 15 February 2016 "Virginia Says Addback Exception Applies Only to Royalties Taxed in Other States" Tax Analysts
  • 4 February 2016 "Pennsylvania DOR Releases Draft Guidance on Addback Provision," Tax Analysts
  • 3 November 2014 "Massachusetts Market Sourcing Regulations" Tax Analysts
  • 21 April 2014 "News Analysis: Does Virginia's Addback 'Clarification' Violate Due Process?" Tax Analysts
  • 7 April 2014 "Virginia Slips 10-Year Retroactive Addback Exception Limit into Budget Bill" Tax Analysts

Credentials

  • Harvard Law School, 1992, J.D., cum laude
  • Yale University, 1989, B.A., magna cum laude

  • Virginia
  • District of Columbia
  • Massachusetts
  • Pennsylvania

  • President, Philadelphia Bar Association State and Local Tax Committee, 2010-2011
  • Secretary, Philadelphia Bar Association State and Local Tax Committee, 2008-2009
  • Tax Section of the American Bar Association
  • Former chair, Boston Bar Association Federal Tax and Business Transactions Committee