Jeffrey A. Goldman
Areas of Focus
State and Local Tax
Tax Controversy and Litigation
Tax Practice Financial Services
, University of Chicago Law School
, Order of the Coif
, University of Wisconsin-Milwaukee
New York (inactive)
U.S. Tax Court, 1997
U.S. Court of Appeals, Ninth Circuit, 1997
U.S. District Court, Southern District of New York, 1992
Jeffrey Goldman has a wealth of experience in taxation of business enterprises, including corporate and partnership taxation, state and local tax, international tax and tax controversy. He has more than 25 years of experience representing clients in complex tax matters.
Jeff frequently advises clients on structuring complex domestic international transactions; mergers and acquisitions; and financing transactions, restructurings, and reorganizations. He also handles complex tax controversies at audit, before the IRS Appeals Division and in court. Jeff has been involved in some of the largest tax controversies in the U.S., amounting to over $75 billion in tax adjustments.
Jeff has experience in providing tax counsel to clients various industries, including:
Insurance and financial services
Jeff also advises clients on tax compliance issues and has represented numerous clients in connection with reporting foreign financial accounts and compliance with the Foreign Account Tax Compliance Act. He also handles state tax matters involving nexus, income tax and apportionment, sales and use tax, and voluntary disclosures.
Law Clerk for the Honorable Charles L. Levin, Michigan Supreme Court, 1990-1991
American Bar Association
Olympia Fields Country Club
Represented real estate investment firm with portfolio of real estate of approximately $50 million in connection with restructuring of business operations to provide for continued acquisitions and expansion in tax efficient manner.
Represented private equity firms in acquisitions and sales of portfolio companies in transactions valued from $5 million to $2.5 billion.
Represented a public multinational in the U.S. Tax Court in connection with an IRS challenge to a cross-border “basis bump” acquisition, where the Tax Court ruled in favor of the taxpayer’s claim for stepped-up basis in assets despite finding strong tax motives for the transaction. Affirmed by the Court of Appeals for the Ninth Circuit.
Representing large public communications entity in Tax Court case involving corporate reorganization and issues of economic substance.
Represented large public transport company in case involving offshore insurance, where the Court of Appeals for the Eleventh Circuit ultimately issued a ruling in favor of the taxpayer, finding that coverage provided by an offshore insurer was true insurance for tax purposes and had true economic substance.
Represented large issuer of annuity contracts in IRS audit and Appeals in matter involving IRS adjustments of over $50 billion.
Five Key Takeaways: Investment In Federal Opportunity Zones Webinar
Publications & Presentations
Opportunity Zones: IRS Proposed Regulations for OZ Funds
October 24, 2018
IRS Issues Proposed Regulations for Qualified Opportunity Zone Funds
New Tax Program Incentivizes Long-Term Investment in Distressed Areas
Tax Cuts and Jobs Act: A Summary of Key Components
Tax Cuts and Jobs Act Update: Senate Approval Moves Bill Forward
Tax Cuts and Jobs Act Update: Key Differences Between the House and Senate Bills
Update: Three Significant Takeaways from the Tax Cuts and Jobs Act
House Releases Tax Bill: Talking Points and Takeaways
Polsinelli Adds Tax Attorney Jeffrey Goldman in Chicago
July 5, 2017
Opportunity Zones Webinar: IRS Proposed Regulations for OZ Funds
October 24, 2018
"My goal is to help clients achieve their business goals with the best tax results, and not to compromise their goals because of tax."
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