John M.Allan

Partner

(T) 1.404.581.8012

John Allan has assisted clients in addressing state and local taxes for 29 years and has handled tax matters in almost all of the 50 states. In addition, he assists clients in addressing state and local tax issues related to corporate reorganizations. He regularly represents clients before state tax agencies and in proceedings before the Multistate Tax Commission.

He has advised clients in the manufacturing, transportation, financial services, telecommunication, hospitality, distribution, and retail industries.

John previously served as editor-in-chief of the American Bar Association's State and Local Tax Lawyer. He is former chair of the Georgia Department of Revenue's Advisory Committee and of the Southeastern Association of Tax Administrators (SEATA) Advisory Council. John is the immediate past chair of the State Bar of Georgia Tax Section. He also chaired the Georgia Bar Tax Section's Tax Court Task Force, which was instrumental in the enactment of legislation creating Georgia's Tax Tribunal in the 2012 Georgia Legislative session.

John speaks frequently on state and local tax matters before such groups as the Council on State Taxation, the Institute for Professionals in Taxation, the Tax Executives Institute (TEI), the Federation of Tax Administrators, and SEATA. Articles coauthored by John and published in The State and Local Tax Lawyer include: "Commerce Clause Implications of Locally Imposed Gross Receipts Based Taxes," Vol. 8, 2003; "Defending Against a Geoffrey Assessment: Statutory Problems Inherent in Economic and Intangible Based Nexus Theories," Vol. 3, 1998; and "The Extraterritorial Assertion of State Taxing Power: Onward to the Past," Vol. 2, 1997.

Experience

  • Ideavillage sells Flawless and Finishing Touch business to Church & Dwight for $900 millionJones Day advised Ideavillage Products Corporation in the sale of its Flawless Finishing Touch business to Church & Dwight for $900 million.
  • Polychem acquired by The Sterling GroupJones Day advised Polychem Corporation in its acquisition by The Sterling Group.
  • Tecum Equity Partners acquires the Gibraltar Cable Barrier Systems division of Gibraltar MaterialsJones Day represented Tecum Equity Partners in connection with its acquisition of the Gibraltar Cable Barrier Systems business, a leading manufacturer and distributor of high tension cable barrier products designed to contain and redirect errant vehicles from road hazards.
  • Riverside portfolio company acquires Eirene, Inc. d/b/a PracticeMojoJones Day represented The Riverside Company in connection with the acquisition and related financing by portfolio company ProSites, Inc., a leading medical and dental website design firm, of marketing platform Eirene, Inc. d/b/a PracticeMojo, a provider of a cloud-based SaaS software for dental practices.
  • RockWood Equity Partners acquires BJG ElectronicsJones Day advised RockWood Equity Partners LLC in connection with the acquisition and related financing of BJG Electronics, Inc., a distributor and light manufacturer of high reliability electronic components serving the defense, commercial aerospace, and business aviation markets.
  • Diebold sells North America electronic security business to Securitas for $350 millionJones Day advised Diebold, Incorporated in the $350 million sale of its North America-based electronic security business to Securitas AB to accelerate its transformation and better position the company to pursue growth opportunities in the dynamic self-service industry.
  • Sprint amends existing receivables facility to include lease receivables and expands total capacity to $4.3 billionJones Day advised Sprint Corporation, a communications services company, in connection with its $1 billion increase to its existing receivables facility with Mizuho Bank, Ltd.; The Bank of Tokyo-Mitsubishi UFJ, Ltd., New York Branch; and SMBC Nikko Securities America, Inc., each as administrative agent.
  • Georgia-Pacific acquires Temple-Inland Building Products business from International Paper for $750 millionJones Day advised Georgia-Pacific LLC, a subsidiary of Koch Industries, Inc., in its acquisition of the Temple-Inland Building Products business from International Paper Company for $750 million.
  • GE acquires Salof, designer and manufacturer of mini LNG technologiesJones Day advised General Electric Company in its acquisition of the Salof group of companies, designers of mini LNG and CO2 technologies and facilities.
  • National retailer is involved in state tax controversies across U.S.Jones Day has represented a national retailer in state tax controversies across the U.S. pertaining to the refund of sales tax remitted on credit card accounts written off as worthless.
  • Expedia, Hotels.com, and Hotwire secure series of victories in connection with occupancy tax in CaliforniaJones Day secured a series of victories on behalf of online travel companies Expedia, Inc., Hotels.com, and Hotwire LP (the "Expedia Entities") in connection with their ongoing transient occupancy tax ("TOT") litigation with various cities in California.
  • Expedia, Hotels.com and Hotwire defeat Ohio municipalities' hotel occupancy tax claimsJones Day recently secured a significant victory in the Sixth Circuit Court of Appeals on behalf of our clients, Expedia, Hotels.com and Hotwire, in an action brought by several Ohio municipalities, including the cities of Columbus, Dayton and Findlay, against the entire online travel industry for allegedly unpaid hotel occupancy taxes.
  • AGL resolves Georgia Department of Revenue disputes involving centralized property tax assessmentsOn behalf of AGL Resources, Inc., Jones Day resolved disputes with the Georgia Department of Revenue regarding centralized assessments of property tax.
  • Cumulus Media acquires Susquehanna Radio for $1.5 billionJones Day advised Cumulus Media Inc. (Cumulus) in the $1.5 billion acquisition by Cumulus Media Partners, LLC (CMP), a partnership among Cumulus, Bain Capital, The Blackstone Group, and Thomas H. Lee Partners, of the radio business of Susquehanna Pfaltzgraff Co.
  • Home improvement retailer obtains favorable outcome in Texas franchise tax hearingJones Day represented a major home improvement retailer in a Texas franchise tax hearing involving the ability to claim capital investment and jobs creation credits.
  • Additional Publications

    • December 2004One Statute, Two Interpretations of Legislative Intent: The Georgia Courts Address the Research Tax Credit, Jones Day State Tax Return
    • November 2004Business Purpose Doctrine, TEI Dallas Chapter
    • November 2004Corporations That Licensed Intellectual Property to Restaurants Deemed Subject to North Carolina Income and Franchise Tax, Jones Day State Tax Return
    • November 2004Federal and State Tax Shelter Developments, TEI Dallas Chapter
    • November 2004Multi-state State Tax Update 2004, TEI Dallas Chapter
    • November 2004Tax Reserves, Tax Planning and Workpapers: 'Are My Tax Documents Privileged?' TEI Dallas Chapter
    • November 2004Taxpayer Fails to Catalyze the Tennessee Court of Appeals to Expand the Industrial Machinery Exemption, Jones Day State Tax Return
    • April 2004Sarbanes-Oxley Implications for the SALT Professional, COST, Baltimore, MD
    • March 2004Run, Here Come the Cops - Troublesome New California Anti-Tax Shelter Provisions; Recent MTC Tax Shelter Report and Activities, Jones Day State Tax Return
    • January 2004Business Purpose and State Tax Shelter Legislation, TEI Dallas Chapter's Current Developments Tax Seminar
    • January 2004Corporate Governance 2004 - Independence and Your Tax Department: Disclosure, Reserves, Working With Your Auditor and Your Audit Committee, etc., TEI Dallas Chapter
    • January 2004Intangible Holding Companies: M&A Apportionment, Nexus and Texas Implications, TEI Dallas Chapter
    • January 2004State Tax Update 2004 on Intangible Holding Companies, TEI Dallas Chapter
    • December 2003In Texas, Form Over Substance Rules: Comptroller Makes an End Run Around Statutory Prohibition of Push Down Accounting, Jones Day State Tax Return
    • July 2003Business Purpose: It Has to Make Sense, SEATA, Savannah, GA
    • June 2003Maryland Highest Court Rules on Intangibles Holding Companies, Jones Day State Tax Return
    • June 2003The Empire Strikes Back - New York Tax Appeals Tribunal Overturns Favorable Decision in Sherwin-Williams, Holds Sherwin-Williams Responsible for Filing Combined Returns With Its Intellectual Property Holding Companies, Jones Day State Tax Return
    • May 2003Different California Courts - Same Result, Jones Day State Tax Return
    • May 2003State Tax Issues of Intercorporate Intellectual Property Transfers, TEI Ashville Chapter
    • April 2003Sarbanes Oxley Revealed! (And What it Means to Your Tax Department), Chicago Tax Club
    • March 2003Georgia Issues Consolidated Return Regulations, Jones Day State Tax Return
    • March 2003Limited Partners Beware - The Alabama Department of Revenue Seeks to Hold Nonresidential Limited Partners Liable for Alabama Personal Income Taxes on Gains and Income Derived by an Alabama Limited Partnership, Jones Day State Tax Return
    • March 2003The Final Auditor Independence Regulations: New Considerations for Corporate Tax Departments, Jones Day State Tax Return
    • March 2003The Final Auditor Independence Regulations: New Considerations for Corporate Tax Departments, Jones Day State Tax Return
    • February 2003Impact of the SEC Final Rules under the Sarbanes-Oxley Act of 2002 on Non-Audit and Tax Services Provided by Auditors
    • 2003Commerce Clause Implications of Locally Imposed Gross Receipts Based Taxes, The State and Local Tax Lawyer, Vol. 8
    • July 2002Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 10
    • May 2002Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 8
    • March 2002Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 6
    • June 2001Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 9
    • January 2001Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 4
    • December 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 3
    • October 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 1
    • September 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 12
    • June 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 9
    • April 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 7
    • January 2000Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 4
    • 1998Defending Against a Geoffrey Assessment: Statutory Problems Inherent in Economic and Intangible Based Nexus Theories, The State and Local Tax Lawyer, Vol. 3
    • 1997The Extraterritorial Assertion of State Taxing Power: Onward to the Past, The State and Local Tax Lawyer, Vol. 2

    Speaking Engagements

    • January 28, 2019
      When Tax Plans Become Tax Gambling; The Risks of Not Planning for Litigation, Jones Day 2019 Atlanta CLE Academy
    • November 12, 2018
      Tax Gambling -- Not Planning for Litigation
    • January 25, 2018
      The Tax Cuts and Jobs Act: A Conference with the Government and Private Sector to Discuss the Legislation
    • February 13, 2017
      Looking into the Crystal Ball: What You Need to Know About Tax Reform & the Future of the Affordable Care Act, Jones Day CLE Academy
    • June 30, 2016
      Chaos in Nexus Land
    • November 13, 2015
      American University Law Review Annual Symposium: Taxing Remote Sales in the Digital Age
    • October 29, 2015
      Webinar: Comptroller v. Wynne
    • May 19, 2015
      Tax Executives Institute New York Chapter State and Local Tax Conference
    • May 14, 2014
      State Tax Cases, Issues, and Policy Matters to Watch, including Certain Federal Legislation, Council On State Tax 2014 Mid-Atlantic Regional State Tax Seminar
    • October 24, 2013
      Navigating Recent Developments on Sales Taxes and Other Transaction Taxes, Counsel on State Taxation (COST)
    • May 6, 2013
      Unraveling the Complexities of the Sales Factor Computation, Tax Executives Institute (TEI)
    • April 23, 2013
      State Tax Litigation Update Around the Country, Counsel on State Taxation (COST)
    • April 23, 2013
      Discussion of State Tax Cases, Issues and Policy Matters to Watch in 2013 & Beyond – Including Certain Federal Legislation, Council on State Taxation ("COST") North Atlantic Regional State Tax Meeting
    • February 26, 2013
      Legislation and Litigation Update in the Eastern United States, Counsel on State Taxation (COST)
    • November 16, 2012
      Georgia DOR One Day Program - Georgia Tax Tribunal, Institute for Professionals in Taxation (IPT)
    • June 20, 2012
      National Trends & Recent Developments and Federal Tax Reform & State Implications, TEI Atlanta Chapter's State & Local Tax Seminar
    • June 3 - 8, 2012
      Basic Income Tax School, Institute for Professionals in Taxation (IPT)
    • May 24, 2012
      Georgia State & Local Tax Tribunal
    • March 29, 2012
      Maximizing State Tax Credits, Jones Day State & Local Tax
    • December 13, 2011
      State Tax Cases and Issues to Watch and Fair Reflections: Defending Against or Applying Alternative Apportionment, Counsel on State Taxation (COST) Pacific Southwest Regional State Tax Seminar
    • May 25, 2010
      What Corporate Executives Need to Know About Unclaimed Property
    • October 26-31, 2008
      Alternatives to Traditional Income Taxes and 10 Best/Worst Audit and Appeal Practices, Institute for Professionals in Taxation Advanced State and Local Income Tax School
    • August 21-24, 2007
      Capital Stock & Franchise Taxes, Tax Executives Institute (TEI)
    • June 25-26, 2007
      Institute for Professionals in Taxation 2007 Annual Conference
    • May 6 - 11, 2007
      2007 IPT Advanced Income Tax School
    • May 2, 2007
      TEI Orange County State & Local Tax Update
    • November 14, 2006
      TEI Atlanta Chapter on State Tax Developments
    • November 2004
      Multi-state State Tax Update 2004, Tax Executives Institute Dallas Chapter
    • November 2004
      Tax Reserves, Tax Planning and Workpapers: 'Are My Tax Documents Privileged?' Tax Executives Institute Dallas Chapter
    • November 2004
      Federal and State Tax Shelter Developments, Tax Executives Institute Dallas Chapter
    • April 2004
      Sarbanes-Oxley Implications for the SALT Professional, COST Baltimore, MD
    • January 2004
      Business Purpose and State Tax Shelter Legislation, Tax Executives Institute Dallas Chapter
    • January 2004
      Intangible Holding Companies: M&A Apportionment, Nexus and Texas Implications, Tax Executives Institute Dallas Chapter
    • January 2004
      Corporate Governance 2004 - Independence and Your Tax Department: Disclosure, Reserves, Working With Your Auditor and Your Audit Committee, etc., Tax Executives Institute Dallas Chapter
    • January 2004
      State Tax Update 2004 on Intangible Holding Companies, Tax Executives Institute Dallas Chapter
    • July 2003
      Business Purpose: It Has to Make Sense, SEATA Savannah, GA
    • May 2003
      State Tax Issues of Intercorporate Intellectual Property Transfers, Tax Executives Institute Ashville Chapter
    • April 2003
      Sarbanes Oxley Revealed! (And What it Means to Your Tax Department), Chicago Tax Club
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