대표 경험

• Outside tax counsel to one of the nation’s largest tax-exempt social welfare organizations on tax, tax exemption, advocacy, and governance issues.
• Outside tax and corporate governance counsel to the leading U.S.-based international software industry trade association, including its for-profit and charitable affiliates.
• Outside tax and corporate governance counsel to a nationwide tax-exempt public broadcasting organization, relating to fundraising and endowment activities, bylaws and internal governance guidelines, and general tax and advocacy matters.
• Advising many nonprofit organizations on creation and operation of for-profit affiliates, including affiliated investment funds with outside investors.
• Representing property and casualty insurers in defending their loss reserve deductions against IRS challenge, and addressing other complex P&C insurance company tax issues.
• Served as taxpayer’s counsel in Acuity Insurance v. Commissioner of Internal Revenue, a leading tax precedent on insurance loss reserves.
• Tax and transactional counsel to a nationwide multi-campus nonprofit university, including its conversion from for-profit to nonprofit status.
• Representing the credit union system and individual state-chartered credit unions on the unrelated business tax consequences of insurance and financial products, negotiating with the IRS on unrelated business tax issues, and representing the industry in successful test-case lawsuits in federal court.
• Continuing work for a wide variety of educational organizations, religious organizations, private foundations, social welfare organizations, trade associations, and other tax-exempt, and nonprofit organizations in all facets of their operations.