Syracuse Chapter Taxation Conference

Dan is a member of the firm's Tax Practice. Licensed in both New York and Florida, Dan focuses on state and local tax matters, and regularly advises individuals and businesses on different aspects of New York State and New York City personal income tax, sales and use tax, corporate franchise tax, and several other lesser-known taxes. While focused on tax matters, Dan often counsels clients on a wide variety of legal matters, teaming up with his colleagues in different disciplines to deliver creative, pragmatic, and efficient solutions. Dan’s clients frequently rely on his guidance for: tax planning for significant liquidity events; changing or establishing state and local tax residency; income, franchise and sales tax substantial nexus issues; complex business income and earnings allocation issues; and related matters. He has extensive experience representing taxpayers in audits conducted by several tax jurisdictions, and also represents taxpayers at various levels of tax controversy dispute resolution and appeal. Dan enjoys the opportunity to share his views on current state and local tax topics and legislative developments through speeches and in articles published in a variety of state and local tax publication

Bill concentrates his practice on federal and international tax law matters, including guiding Canadian and other non-U.S. clients on U.S. tax matters. He has comprehensive experience advising clients on business expansion into the United States, structuring considerations in purchasing U.S. real estate, choice of entity decisions, the tax implications of relinquishing U.S. citizenship or residency status, the application of the CFC and PFIC U.S. anti-deferral regimes, and the new tax reform rules, including the Code section 199A deduction for pass-through entities and the interest deductibility limitations. Bill also has broad experience working on tax controversy matters, including advising clients on voluntary disclosure options, IRS audits, and U.S. Tax Court matters. He also works with a variety of tax-exempt organizations and private foundations on obtaining and maintaining tax-exempt status. Bill is also a member of the firm’s Oil & Gas Practice, where he provides advice and guidance on the tax implications for private placements.

Heather is a member of the firm’s Business and International Tax Practices, where she advises businesses, individuals, and non-profit organizations on tax-related matters and planning. Prior to joining Hodgson Russ as an attorney, Heather worked for the firm on a part-time basis during her last year in law school, and was also a summer associate. During law school, Heather interned for the Honorable Lawrence J. Vilardo in the U.S. District Court for the Western District of New York and the U.S. Attorney’s Office for the Western District of New York. Prior to attending law school, Heather worked for NFL Films as a project manager.

Andrew’s practice deals with all aspects of state and local tax (SALT). Though his primary focus is on New York State and New York City matters, Andrew handles multistate SALT matters as well. Andrew has in-depth experience in the area of state tax residency and assists clients from the planning stage through the audit and appeal processes. Andrew counsels clients planning moves out of states like New York on how to accomplish their moves in ways most likely to be accepted by state taxing authorities on audit, while also allowing the clients to maintain some connections to their former home state. He also counsels clients, often in connection with a change of residence, on structuring transactions and ongoing business relationships to minimize the taxes owed by clients to states in which they are non-residents. While Andrew prefers to advise clients on the front-end of a move, he also understands that many clients will only seek his counsel after they’ve received an audit notice. Andrew has extensive experience defending clients’ residency changes in the audit context. Andrew is a tenacious advocate for his clients. When audits or administrative tax litigation is involved, Andrew rolls up his sleeves and goes head-to-head with auditors and lawyers representing the state tax departments. In the residency space, Andrew has successfully represented hundreds of clients in audits and well over 100 clients in appeals of contested residency audits. Andrew's experience in residency matters also extends to 548-day rule and 30-day rule planning and audits. He has successfully helped many clients plan for, execute, and defend on audit, 548-day rule and 30-day rule strategies, which resulted in nonresident status in New York. Clients he assists in these matters include: New Yorkers wishing to minimize state and/or city tax on discrete liquidity events, US expatriates working abroad, and those wishing to change their residency to a foreign country. Andrew is also involved in a host of other New York tax controversy work. Recent matters include – audits and appeals dealing with the application of the New York’s MCTMT to limited partner income, Article 9A corporate apportionment audits, and New York sales and use tax audits and appeals. Finally, Andrew is heavily involved in the area of multistate tax compliance for cross-border businesses. In conjunction with appropriate federal and international tax planning, Andrew advises on U.S. state and local tax compliance issues to identify tax liability and risk concerns for cross-border businesses. Once the compliance issues are identified, Andrew works with these businesses to resolve past compliance issues and ensure compliance on a go-forward basis.

Joe counsels clients on a wide range of state and local taxation issues and represents taxpayers in disputes with the New York State Department of Taxation and Finance as well as the New York City Department of Finance. As the Sales & Use Tax Practice Leader, Joe’s practice focuses on sales and use tax issues, especially in the technology (software as a service, cloud computing, digital products, etc.), fine arts and construction industries. Joe is the primary author of our firm’s sales tax blog, All About Sales Tax. Joe is a contributing editor (New York Chapter) of the American Bar Association's Sales and Use Tax Deskbook. Joe also counsels clients regarding personal income tax planning and residency issues. He co-authored, with Mark S. Klein, the 2019 Guidebook to New York Taxes, a reference source of information on this topic and he writes a column for Tax Notes State called “The Endres Assessment." He also advises clients with respect to various federal and state tax incentive-based programs such as the federal renewable energy investment and production tax credits, New York State's Start-Up NY Program, the Excelsior Program, the former Empire Zone Program, the Brownfield Tax Credit Program and the Historical Building Rehabilitation Tax Credit Program. As the Abandoned Property Audits Practice Leader, Joe counsels clients in this area of law and has represented large corporations in complex compliance matters such as multistate abandoned property audits and voluntary disclosures.

Nate, a second-generation estates and trusts lawyer, concentrates his law practice in all aspects of estates and trusts law. He helps a wide range of clients (primarily high-net-worth individuals and families, business owners, entertainers, managers and executives of investment firms, real estate developers and investors, and health care professionals) construct complex estate plans, often with a multi-generational, multi-jurisdictional (including international), and creditor protection focus. Nate also counsels fiduciaries and beneficiaries on all aspects of estate and trust administration, including contested matters. Many of Nate's clients consider him an outside "general counsel," and seek his guidance on a variety of legal matters. If Nate is not the right person to handle a particular matter, he collaborates with other members of the Firm to get his clients the best possible advice. Nate takes a concierge approach to his practice. He regularly meets with clients outside of the normal workday, travels to their residences, social clubs, and more. He recognizes that his clients are busy people, and makes every effort to accommodate their schedules. Nate is a regular speaker on estates and trusts topics. In addition to his speaking engagements, he authors the estate planning chapter of the publication Taxation of Distributions From Qualified Plans, a leading treatise on the issue of taxation of individual retirement accounts (IRAs) and 401(k)s that is published by Thomson Reuters as part of its Checkpoint WG&L Tax Series. Nate divides his time among the firm’s New York City, Hackensack, and Buffalo offices.

As a member of the State and Local Tax (SALT) Practice, Joseph (Joe) works with clients to navigate New York State’s vast system of tax laws. His primary focus is on New York State and New York City taxes, but he also counsels clients on multistate SALT matters, including sales tax and various business taxes. Joe works to simplify the ins-and-outs of the New York State Department of Taxation and Finance for his clients. During his tenure, he has worked extensively with Department of Taxation personnel, which has given him insight into what auditors look for, allowing him to craft nuanced strategies focused on efficiently resolving each client’s audit. Joe understands that the best way to win a residency audit is to plan ahead. He counsels clients moving out of New York State through the entire audit process from start to finish – including helping to develop a legally-grounded strategy for a move that aims to help clients strengthen their change of domicile position and decrease their audit risk. Joe also assists clients looking to move out of California. When a client is met with an audit notice, Joe focuses on not only easing that burden for his client, but also quickly and proficiently working through the process in order to obtain an economical outcome. When working with clients to help resolve tax disputes, Joe crafts unique and individualized approaches for each scenario. He understands that not all clients are the same and develops distinctive solutions for each case. In addition to his work with clients, Joe also is the host of the first ever Hodgson Russ LLP podcast, “State Tax Talks with Joe Tantillo.” As the host, Joe works to un-complicate some of New York State’s most complicated tax laws and requirements for listeners, bringing in SALT experts to provide additional commentary on current issues faced by taxpayers around the United States. Joe is a regular contributor to the Noonan’s Notes tax blog, and has published several articles on various topics in the world of SALT. Joe also enjoys public speaking on tax topics, and has presented on SALT issues both in person and in Webinars. Joe is licensed to practice in New York State, California, and Washington, D.C.