Richard C. Call focuses his practice on a broad range of state and local tax matters, including litigation, advisory, and transactional work. He represents clients in proceedings before administrative bodies, trial courts, and appellate courts across multiple jurisdictions.

Corporate Income Tax Litigation and Transactions: Richard has significant experience with all major areas of corporate income tax, advising clients on complex issues such as nexus, apportionment, addbacks, transfer pricing, and combination . He represents clients on transfer pricing and alternative apportionment issues in various states, including Alabama, Louisiana, and South Carolina. He also regularly works with clients to evaluate and efficiently structure state income and franchise tax related to mergers, acquisitions, and other strategic transactions.

Sales Taxes and Company Business Models: Richard advises clients on sales tax issues that are affecting their overall business models, helping companies structure transactions to mitigate sales tax exposure, which often results in significant savings. As states increasingly expand the taxation of software, digital products, and services, he assists companies in identifying and managing their exposure to such taxes, particularly in advance of mergers, acquisitions, and other liquidity events.

Personal Income Tax Residency: Richard routinely advises clients on residency for various states, including New York, Massachusetts, California, and Illinois

Speeches and Publications: Richard frequently speaks on state and local tax issues and has presented before organizations such as the NYU SPS Annual Institute on State and Local Taxation, the Council On State Taxation, the Tax Executives Institute, and the Practising Law Institute. He also publishes frequently on state and local tax topics, with articles appearing in several publications, including Tax Notes State, Bloomberg BNA Weekly State Tax Report, Bloomberg BNA Multistate Tax Report, Tax Executive, Journal of State Taxation, Boston Business Journal, and NYU SPS Annual Institute on State and Local Taxation.

Michael Hilkin represents clients in all aspects of complex state and local tax matters. He has a particular focus on tax controversy and transactional issues relating to state and local income, franchise, sales and use, gross receipts, and other business taxes. Michael has extensive experience handling state and local tax issues before US administrative and judicial systems, including arguing cases before state courts and state supreme courts. He also regularly advises clients on personal income tax issues, especially those concerning residency.

Michael frequently speaks on state and local tax issues before the Council on State Taxation, Tax Executives Institute, the New York University Institute on State Taxation, the Paul J. Hartman SALT Forum, and the Institute for Professionals in Taxation.

Michael Hilkin represents clients in all aspects of complex state and local tax matters. He has a particular focus on tax controversy and transactional issues relating to state and local income, franchise, sales and use, gross receipts, and other business taxes. Michael has extensive experience handling state and local tax issues before US administrative and judicial systems, including arguing cases before state courts and state supreme courts. He also regularly advises clients on personal income tax issues, especially those concerning residency.

Michael frequently speaks on state and local tax issues before the Council on State Taxation, Tax Executives Institute, the New York University Institute on State Taxation, the Paul J. Hartman SALT Forum, and the Institute for Professionals in Taxation.

Frank J. Jackson focuses his practice on federal and state tax controversies at every stage, including tax audits, administrative appeals and litigation. Over the last two decades, Frank has successfully represented domestic and multinational businesses, nonprofits and high-net-worth individuals and estates in disputes involving a wide variety of sophisticated tax matters.

At the examination and appeals stages of tax controversies, Frank achieves client goals through his substantive and procedural knowledge, strong communication and negotiation skills and innovative strategies. When litigation cannot be avoided or is in his client’s best interest, he provides effective representation in hearings and trials before the US Tax Court and US district courts. In cases where tax liabilities have been assessed but not paid, Frank represents clients before the Internal Revenue Services’ (IRS) Collection Division, including in the negotiation of installment agreements, offers in compromise and in resolving lien priority and levy disputes.

Frank has firsthand understanding of the priorities and processes of tax authorities. Early in his career, he served as a trial lawyer and National Tax Shelter Project lawyer for the IRS. In this capacity, he represented the agency in suits before the Tax Court and provided legal advice to revenue agents and officers.

Additionally, Frank handles sensitive tax matters involving fraud allegations and has extensive experience helping clients avoid penalties and criminal charges. To help US taxpayers ensure compliance with federal and state tax laws, he offers counsel on voluntary disclosure initiatives, including previously undisclosed foreign financial accounts, and regularly helps clients correct compliance errors.

Frank is also an avid writer and public speaker on tax law topics.

Michael J. Scarduzio focuses his practice on US and international tax matters, particularly civil and criminal tax litigation. From audit to litigation, he represents taxpayers in all phases of tax controversy, including novel issues of first impression such as financial hedging transactions using a captive insurer, US tax implications of a foreign master-feeder fund’s investment activities and matters arising under Internal Revenue Code (IRC) Sections 7216 and 7212(a).

Michael has experience handling a variety of complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), international tax and Report of Foreign Bank and Financial Accounts (FBAR) compliance, reportable transactions, transfer pricing, debt equity classifications, foreign tax credits and excise tax on reinsurers. He also advises on questions relating to the attorney-client and work product privileges arising in tax matters.

After law school, Michael served as a term law clerk for the Honorable Karen L. Hayes of the US District Court for the Western District of Louisiana. He also served as a judicial intern for the Honorable Dolores K. Sloviter of the US Court of Appeals for the Third Circuit during law school. And, while earning his LLM in Tax from NYU, he served as a legal extern for the Internal Revenue Service’s (IRS) Office of Chief Counsel and Large Business and International Division in New York.

Michael has contributed to several publications, including co-authoring articles in the Journal of Tax Practice & Procedure addressing potential abuse of CARES Act tax relief provisions, the BBA centralized partnership audit regulations, and the repeal of the TEFRA audit regime. He has also co-authored an article examining the United States’ role as a potential tax haven, published in The Champion.

John T. Lutz advises clients on the tax aspects of investment funds, structured finance, derivatives and structured products. He also counsels clients on matters related to insurance products, investment tax credits, conventional US and cross-border securities offerings, and corporate mergers and acquisitions. John represents a number of tax-exempt organizations in connection with their investment activities and incentive compensation arrangements.

John handles all aspects of tax-advantaged financings and investments for financial institutions, investment fund managers, high net worth individuals, and investors. He represents banks and investment managers in connection with asset backed securities including collateralized loan obligations, structured notes, and repackagings.

John is a recognized leader in the tax aspects of municipal derivatives and tax-exempt bond securitizations. He provides tax advice to derivative products dealers in the domestic and cross-border contexts, advising on US and international tax issues related to insurance products, equity swaps, repurchase agreements, structured notes, and offshore structured finance vehicles.