Jeffrey A. Friedman, Partner
700 Sixth Street, NW Suite 700 Washington, DC 20001-3980 Office: 202.383.0718 [email protected]Honored as “Tax Lawyer of the Year” in 2011 by State Tax Notes, Jeff Friedman provides sophisticated state and local tax planning, strategic advice and advocacy to numerous Fortune 100 and industry-leading companies. His comprehensive practice includes state and local tax planning, compliance, legislation and policy, and litigation and controversy matters involving income, franchise, sales and use and property taxes. Jeff’s clients span a variety of industries, including e-commerce, energy, technology and telecommunications.
A recognized thought leader on state and local tax issues, Jeff works on high-profile and precedent-setting litigation and controversy matters across the country. These matters impact critical questions on nexus, apportionment, the Multistate Tax Compact and the equal protection, due process and commerce clauses of the United States Constitution. Jeff is also a well-respected advocate on issues of tax policy, including the taxation of digital economy transactions. Prior to joining Sutherland, Jeff was a partner in KPMG’s Washington national tax practice; served as an attorney-adviser in the U.S. Department of the Treasury’s Office of Tax Policy, where he assisted with the development of the U.S.
government's position on domestic and international electronic commerce tax issues; and served as vice president and counsel of the Committee (now Council) On State Taxation (COST).
Experience
Sutherland wins constitutional challenge of “excise tax,” which federal court affirms on appeal.
Sutherland advises leading online retailer about state tax issues.
Sutherland saves Fortune 100 tech firm $70 million in potential Washington State sales tax liability.
Awards and Rankings
State Tax Notes “Tax Lawyer of the Year” (2011)
Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2012-2014)
Related Practices / Industries
• Tax
• State and Local Tax • Tax Controversy & Litigation • Appellate
• Insurance
• Unclaimed Insurance Benefits • Digital Economy
• Technology, Media &
Telecommunications Transactions
Bar Admissions
• District of Columbia • Maryland
Recognized by The Legal 500 United States in the areas of tax (2012) and tax controversy (2011-2012)
Professional Activities
Adjunct Professor, Georgetown University Law Center’s State and Local Tax course offered as part of its LL.M. program
Faculty Member, Council On State Taxation Income Tax School Faculty Member, Tax Executives Institute’s State and Local Tax School
Articles
Maryland Seeks Cash, Not Credit, Before Supreme Court (November 13, 2014)
Law360
State Conformity to Federal Income Taxation of Foreign Corporations (November 3, 2014)
State Tax Notes and Tax Notes International
State Tax Nexus Case Study: Taxation of Foreign E-Book Sellers (August 22, 2014)
Bloomberg BNA: Tax Management Weekly State Tax Report
A Pinch of SALT: Maryland’s Gore-y Nexus Standard: Out-of-State Holding Companies Subject to Tax (April 14, 2014)
State Tax Notes
A Pinch of SALT: Demystifying the MTC Joint Audit Program (May 20, 2013) Reprinted with permission from State Tax Notes
A Pinch of SALT: Wynne-ing isn't Everything (April 1, 2013) Reprinted with permission from Tax Analysts
A Pinch of SALT: Applying False Claims Acts in State Taxation (May 7, 2012) Reprinted with permission from State Tax Notes
A Pinch of SALT: Friends With Benefits Received? A Comparison of Market Sourcing Rules (December 5, 2011)
Reprinted with permission from State Tax Notes
A Pinch of SALT: D.C.'s Attempt to Force Remote Sellers to Collect Sales Tax (July 11, 2011)
Reprinted with permission from State Tax Notes
A Pinch of SALT: Waive or Walk: Considerations for Extending the Statute of Limitations (November 1, 2010)
A Pinch of SALT: Applying P.L. 86-272 In a Modern Economy (July 5, 2010) Reprinted with permission from State Tax Notes
A Pinch of SALT: State Tax Issues Resulting From IRS Announcement 2010-9 (May 3, 2010)
Reprinted with permission State Tax Notes
A Pinch of SALT: State RAR Reporting—Simplifying Unnessecary Complexities (March 2010)
Reprinted with permission from State Tax Notes
Employment Tax Withholding Compliance: Sorting Through a Patchwork of Laws (Winter/Spring 2010)
Reprinted with permission from Partnering Perspectives
A Pinch of SALT: The U.S. Supreme Court Should Accept a Nexus Case (July 9, 2009)
Reprinted with permission from State Tax Notes
A Pinch of SALT: The Loophole of Labeling a Tax Provision a Loophole (September 1, 2008)
Reprinted with permission from State Tax Notes
The Redemption of Equitable Apportionment (September - October 2006) Reprinted with permission from The Tax Executive
Check Your California Receipts: California Supreme Court Should Provide Appropriate Standards For Equitable Apportionment (September 5, 2005) Reprinted with permission from Tax Analysts
Filling State Coffers (October 25, 2004) Posted with permission from Legal Times
Presentations
Transfer Pricing Developments and MTC Initiatives (April 22, 2015) TEI Dallas/Forth Worth Tax School
Cable Tax Policy Meeting (March 30, 2015)
Addressing State and International Tax Overlaps (March 23, 2015) TEI 65th Midyear Conference
State Tax Legislative, Judicial and Administrative Developments - What's Happened and What's on the Horizon (February 6, 2015)
The SALT Effect: State Tax Responses to Corporate Inversions (December 11, 2014)
NCSL Forum
State Tax Litigation and Controversy Update (December 9, 2014) TEI/IPT SALT Day
Reserves - Release or Forever? (December 9, 2014) TEI/IPT SALT Day
Cloud Computing - Is the Sky Clearing? (December 9, 2014) TEI/IPT SALT Day
NYU Institute on State and Local Taxation (December 8, 2014) National Developments (November 5, 2014)
MACPA-MSBA Advanced Tax Institute
Paul J. Hartman State and Local Tax Forum (October 28-30, 2014) BTI 2014 Annual Conference (October 19-22, 2014)
Through a Blurred Lens - Update on State Tax Transparency Developments (October 9, 2014)
Sutherland Tax Roundtable - Silicon Valley
Sutherland Tax Roundtable Silicon Valley (October 9, 2014)
NESTOA 2014 Annual Conference (September 28-October 1, 2014) Federal Legislation and National Trends (September 23, 2014) IPT Sales Tax Symposium 2014
SALT Employment Taxes: Withholding and Other Obligations for the Mobile Workforce (September 17, 2014)
TEI Seattle Chapter Meeting
State Tax Litigation and Controversy Update (September 17, 2014) TEI Seattle Chapter Meeting
The Three Great Issues the U.S. Supreme Court Has Not Answered: A Panel Discussion with Practical Guidance and Best Practices Provided by Practitioner, Industry, and Government Representatives (August 8, 2014)
The Source Code: Unraveling and Reconciling State and International Tax Sourcing Methods (June 17, 2014)
Sutherland SALT Roundtable - Silicon Valley
Sutherland SALT Roundtable Silicon Valley (June 17, 2014)
On Cloud 9: Almost 10 Use Cases of Cloud Taxation (June 9, 2014) TEI Region VIII Conference
National Litigation Update and a Review of New York Tax Changes (May 28, 2014)
TEI Houston Chapter Meeting
Industry-Specific Nexus Issues (May 15, 2014) STARTUP Spring 2014 Conference
Information Sharing and Transparency (May 14, 2014) TEI Denver Chapter SALT Update
Shifting Apportionment Landscape (May 14, 2014) TEI Denver Chapter SALT Update
Expanding the Borders: States Seeking to Reach Extraterritorial Income (April 29, 2014)
COST Spring Audit Session/Income Tax Conference
State Tax Audit Best Practices for the In-house Professional (March 24, 2014) TEI Midyear Conference
State and Local Tax Update (March 21, 2014) TEI Carolinas Chapter Meeting
Sales Tax Syndromes: Bundling, Digital Goods & Separately Stating Tax (March 19, 2014)
TEI Virginia Chapter Meeting
Tax Planning in Today’s Controversy/Litigation Environment and State Tax Controversy Update (March 19, 2014)
TEI Richmond Chapter Meeting
Legislative and Administrative Update on State Sales Taxation of Business Services and State Controversy Update (March 5, 2014)
Sales Tax Syndromes: Bundling, Digital Goods, and Separately Stating Tax (February 18, 2014)
TEI Minnesota
Legislative, Judicial and Administrative Developments in State Taxation (February 7, 2014)
The National Multistate Tax Symposium
New York University 32nd Institute on State and Local Taxation (December 12-13, 2013)
State Tax Assessments and Controversies - The Lay of the Land (July 22-25, 2013)
MTC Annual Conference
How the Interstate Tax System Works/Jurisdiction & Nexus (June 19-21, 2013) Interstate Tax Corporation Interstate Tax Planning Conference
Hot Topics in State Income Tax (June 13, 2013)
Deloitte Center for Multistate Taxation 17th Annual Multistate Tax Institute State Tax Update (June 9-12, 2013)
TEI Region VIII Conference
State and Local Tax Watch List (May 16-17, 2013) Media Industry Tax Conference
Determining the Corporate Income Tax Base (April 29-May 2, 2013)
Council on State Taxation Intermediate/Advanced State Income Tax School U.S. Branches of Foreign Corporations (April 18, 2013)
NYU/KPMG 12th Annual Tax Lecture Series
Transaction Tax Cases and Issues to Watch in 2013 (February 24-27, 2013) COST Sales Tax Conference and Audit Session
State and Local Nexus Expansion (February 22, 2013) UW/TEI Tax Forum
Legislative and Administrative Developments in State Taxation (February 6-8, 2013)
Around the World in 120 Minutes: Year-End Corporate Tax Round-Up (December 13, 2012)
TEI/Thomson Reuters Webcast
The Cats and Dogs of Sales Tax: Bundling, Absorption and Other Furry Creatures (December 4, 2012)
COST Pacific Northwest Regional Meeting
Review and Preview of Federal Constitutional Issues (November 30, 2012) New York University Institute on State and Local Taxation
State Tax Aspects of Attorney Client Privilege and Work Product Doctrine (November 9, 2012)
State Tax Roundtable for Utilities and Power (STARTUP)
National Developments and Trends in State Taxes – Point/Counterpoint Discussion (November 8, 2012)
MACPA/Maryland Bar Association Advanced Tax Institute
A SALTy Countdown – the Top 10 Litigation Cases of 2012 (November 2, 2012) California State Bar Association 2012 California Tax Policy Conference
California Tax Policy Conference (November 1, 2012 - November 3, 2012) California Tax Policy Conference
“Significant Court Decisions Impacting Our Industry” and “Seeking State Tax Fairness: The Need for Federal Adjudication, A Taxpayers Bill of Rights and Federal Preemption Legislation” (October 21, 2012)
Broadband Tax Institute Annual Conference State and Local Tax Update (September 19, 2012) TEI Seattle Chapter Meeting
State and Local Tax Roundtable (July 26, 2012) Sutherland SALT
Leveling the Playing Field (July 24, 2012)
Southeastern Association of Tax Administrators Annual Conference
How the Interstate Tax System Works: Jurisdiction and Nexus (June 27, 2012) Interstate Tax Planning Meeting
TEI Region VII Conference (June 27, 2012 - July 1, 2012) TEI Region VII
FTA Annual Meeting (June 17, 2012) Federation of Tax Administrators (FTA)
Hot Topics in State Income Tax (June 14, 2012) Multistate Tax Conference
State Tax Update (June 11, 2012) TEI Region VIII Tax Conference
State Tax Litigation Update (May 25, 2012)
North Carolina Bar Association - 11th Annual North Carolina/South Carolina Tax Section Annual Meeting
State and Local Taxation Update (May 16, 2012) TEI Denver
2012 Spring Audit Session/Income Tax Conference (May 15, 2012) Council on State Taxation (COST) 2012 Spring Audit Session/Income Tax Conference
SALT Roundtable - Houston (May 10, 2012) Sutherland SALT Roundtable
STARTUP Meeting - Document Management Retention (May 9, 2012) STARTUP
TEI Houston Tax School (May 3, 2012) Tax Executives Institute (TEI)
Determining the Corporate Income Tax Base (April 30, 2012) COST Intermediate/Advanced State Income Tax School
Tax Executives Institute: 62nd Midyear Conference (March 25-28, 2012) Tax Executives Institute
State and Local Tax Session (February 28, 2012) TEI Florida Chapter
State and Local M&A Issues (February 21, 2012) TEI Dallas Chapter Meeting
The National Multistate Tax Symposium (February 3, 2012) The National Multistate Tax Symposium - Orlando
30th New York University Institute on State and Local Taxation (December 12, 2011 - December 13, 2011)
New York University Institute
TEI Virginia Chapter - SALT Seminar (November 17, 2011) Tax Executives Institute
Settled Expectations: Best Practices to Negotiate and Memorialize State Tax Settlements (November 9, 2011)
TEI Philadelphia Chapter Meeting
Recent Developments in Multistate and Local Taxation (October 26, 2011 - October 28, 2011)
60th Annual Tulane Tax Institute
A Day in ‘Court’: Navigating the State and Local Appeal Process (October 6, 2011) IPT Seattle Meeting
Sutherland SALT Financial Services Roundtable (October 5, 2011) Sutherland
State Tax Consequences of Federal Uncertain Tax Positions (September 26, 2011)
Tax Executives Institute Seattle Chapter SALT Meeting
COST Pacific Northwest Regional Meeting (September 22, 2011) Council on State Taxation
Council on State Taxation (COST) North Atlantic Regional State Tax Seminar (August 11, 2011)
Use Tax Collection Issues Developments (July 24, 2011 - July 28, 2011) Multistate Tax Commission’s 44th Annual Conference
Retroactive Tax Legislation (June 26-29, 2011) IPT Annual Conference
TEI Region VII Conference (June 22, 2011 - June 26, 2011) Tax Executives Institute
Jurisdiction and Nexus - Interstate Tax Planning Seminar (June 20, 2011 - June 22, 2011)
Cloud Computing - Focus on the Legal and Policy Issues (June 12, 2011 - June 15, 2011)
2011 FTA Annual Meeting
Top 2011 State Income Tax Cases and Issues to Watch in 2011 (May 18, 2011) TEI Denver Chapter Meeting
MAPI Tax Council II Meeting (May 5, 2011)
Manufacturers Alliance for Productivity and Innovation (MAPI) 61st TEI Midyear Conference (April 4, 2011 - April 6, 2011) Tax Executives Institute
Codified Economic Substance Doctrine: You’ll Know it When You See It? A Guide to Navigating the New Economic Substance (March 30, 2011)
Sutherland Webinar
TEI Seattle Chapter State and Local Tax Update (February 9, 2011) Tax Executives Institute
National Multistate Tax Symposium – Multistate Tax: Navigating an Economy of Transition (February 2, 2011 - February 4, 2011)
National Multistate Tax Symposium
Council on State Taxation 41st Annual Meeting (October 19-22, 2010) Broadband Tax Institute’s 2010 Annual Conference (September 19-22, 2010) State Tax Roundtable – Planning and Techniques (July 22, 2010)
Tax Executives Institute 2010 Region VII Conference Jurisdiction & Nexus (June 21, 2010)
Interstate Tax Corporation’s Interstate Tax Planning Conference COST Pacific Northwest Regional State Tax Seminar (June 17, 2010) Tax Executives Institute Seattle Chapter Meeting (May 12, 2010) The Dangers of Unreliable Intercompany Accounting (April 29, 2010)
Tax Executives Institute Nashville Chapter Spring Seminar
Determining the Corporate Income Tax Base (April 25, 2010 - April 29, 2010)
Council on State Taxation Intermediate/Advanced State Income Tax School Tax Council 2010 Annual Spring Tax Conference (March 27, 2010)
Tax Executives Institute New York Chapter Meeting - State Taxation Update (February 24, 2010)
State and Local Tax Developments – The Dangers of Unreliable Intercompany Accounting in Separate Company States and Other Issues (January 12, 2010) Tax Executives Institute (TEI) Webinar Learning Network
State Tax Policy and Combined Reporting Updates (December 21, 2009)
Council on State Taxation (COST) Mid-Atlantic Regional Tax Seminar
New York University School of Continuing and Professional Studies’ 28th Institute on State and Local Taxation (December 14-15, 2009)
National Developments and Trends in State Taxes – Point/Counterpoint Discussion (November 5, 2009)
Maryland Institute for Continuing Professional Education of Lawyers (MICPEL) and Maryland Association of CPAs (MACPA) Advanced Tax Institute
State Tax Issues for Distressed Companies (October 27, 2009) Tax Executives Institute 64th Annual Conference
Tax Executives Institute’s 64th Annual Conference (October 25, 2009 - October 28, 2009)
State Income Tax - Calculating Your Costs of Performance (October 19, 2009) BTI Annual Conference
Wisconsin Combined Reporting: Background and Discussion Regarding Taxpayer Issues (October 1, 2009)
Council on State Taxation (COST) Mid-West Regional State Tax Seminar State Tax Roundtable – State Tax Planning and Developments (June 9, 2009) Tax Executives Institute Region VII Meeting
State and Local Tax Planning and Unplanning (March 30, 2009) TEI 58th Midyear Conference
State Attacks on Inter-Company Transactions (February 25, 2009) TCPI Conference
Looking Forward—Sales Tax Impact of Federal Legislation (February 4, 2009) The 2009 National Multistate Tax Symposium
NYU Institute on State and Local Taxation (December 15-16, 2008)
15th Annual Paul J. Hartman State and Local Tax Forum (October 28-30, 2008) Council on State Taxation (COST) 39th Annual Meeting (October 22, 2008 - October 24, 2008)
Significant Federal & State Decisions That Impact Telecommunication (October 20, 2008)
Broadband Tax Institute
Tax Executives Institute (TEI) Region VII Conference (July 10, 2008 - July 13, 2008)
Tax Executives Institute 58th Midyear Conference (April 6, 2008 - April 9, 2008) Southwest/West Regional Meeting of the Council on State Taxation (COST) (November 29, 2007)
Tax Executives Institute (TEI) 2007 State and Local Tax Course (August 20-24, 2007)
Tax Executives Institute's 43rd Annual Tax Symposium (December 6, 2006) 60th Annual Tax Executives Institute (TEI) Conference (October 23, 2005) Update on Significant State Tax Litigation (October 18, 2005)
Council on State Taxation (COST) North Atlantic Regional State Tax Seminar Legislative Tax Update (September 27, 2005)
Tax Executives Institute (TEI) Northeast Wisconsin Chapter State Income Tax Planning for Section 965 (July 21, 2005)
Tax Executives Institute (TEI) Bringing the Cash Home: Successfully Navigating the Section 965 Repatriation Provision
Interstate Tax Planning Seminar (June 20-22, 2005)
Institute for Professionals in Taxation 29th Annual Conference (June 19-22, 2005) Reducing Tensions Between Taxpayers and Tax Agencies (June 12, 2005 - June 15, 2005)
Constitutional Foundations of Income and Franchise Taxation (June 6, 2005 - June 10, 2005)
Tax Executives Institute (TEI) Education Fund's 2005 State and Local Tax Course State Tax Planning and Unplanning (May 13, 2005)
Tax Executives Institute (TEI) New Jersey Chapter
Council on State Taxation (COST) 2005 Income Tax Conference/Audit Session (March 15, 2005)
Education
• LL.M., with distinction, Georgetown University Law Center
• J.D., with high honors, University of Maryland School of Law, Managing Editor, The Business Lawyer