In the state tax field, Fred has represented numerous clients in administrative hearings, litigation and tax planning matters. His state tax litigation experience includes unitary business group composition, business and non-business income controversies, financial organizations, income taxation of partnerships, net operating losses, franchise taxes sales, use and excise taxes, nexus and Public Law 86-272, Due Process and Commerce Clause issues, the Illinois Uniformity Clause and other constitutional issues. Fred also consults with clients on a wide variety of state tax planning issues, including state income and franchise tax planning for mergers, acquisitions and corporate restructuring transactions, consolidated and combined return planning, and nexus and interstate commerce issues. Fred’s substantial background in federal income taxation of corporate, partnership and commercial transactions provides for a unique perspective on the intersection between federal and state income tax systems.
In the federal tax field, his practice concerns primarily corporate, partnerships/pass-through and investment transactions, including financial products, domestic and offshore investment funds, real estate investment trusts (REITs) and private equity deals, restructuring of debt and equity and mergers and acquisitions.
Litigation of numerous corporate Illinois income tax cases, including AT&T Teleholdings, Inc. v. Department of Revenue, 2012 IL App (1st) 113053; BP Oil Pipeline Co. v. Department of Revenue, No. 2001-2364 (1st Dist. 2004); and Hercules Incorporated v. Department of Revenue, 324 Ill. App. 3d 329 (1st Dist. 2001)
Counseling Fortune 500 clients on state income and franchise tax consequences of supply chain planning, spin-offs, mergers and acquisitions and corporate restructuring transactions
Federal tax planning for partnership and limited liability company acquisitions, dispositions and restructuring transactions
Martindale-Hubbell, AV Preeminent
Law & Politics 2006 to 2012, Illinois Super Lawyers
Leading Lawyers Network
American Bar Association; Chair, Subcommittee on International Tax Issues of the State & Local Tax Committee, Section of Taxation
Illinois Department of Revenue, Advisory Committee
University of Chicago Law School, JD, 1980
Hamilton College, BA, magna cum laude and with honors, 1977
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