Frank J.Jackson

Partner

(T) + 1.212.326.8329

Frank Jackson has represented clients in all aspects of tax controversies and investigations involving the IRS and the DOJ, as well as state and local tax jurisdictions throughout the United States, for almost 20 years. His practice focuses on every stage of a civil federal tax controversy, including tax audits, administrative appeals, and tax litigation, and criminal tax defense.

Frank represents all types of taxpayers, including multinational corporations, financial institutions, hedge funds, professional services firms, closely held businesses, estates, and high net worth individuals in tax disputes or trials before the U.S. Tax Court and U.S. District Court. In addition, he successfully resolves issues, when best for his clients, without the need for litigation. Where tax liabilities have been assessed but unpaid, Frank represents clients before the IRS Collection Division in negotiating installment agreements, offers in compromise, and in resolving lien priority and levy disputes. He previously served as a trial attorney with the IRS, where he represented the IRS in the U.S. Tax Court and provided legal advice to revenue agents and officers in various matters.

Frank also has significant experience advising investment advisors and funds under IRS examination. He advises U.S. taxpayers in becoming compliant with U.S. and state tax laws through voluntary disclosure initiatives relating to previously undisclosed foreign financial accounts, sensitive issue civil tax examinations where substantial civil penalty issues or possible assertions of fraudulent conduct may arise, and in defending criminal tax fraud investigations. An active member of the American Bar Association's Taxation Section, Frank speaks regularly at tax law conferences and has written about tax issues.

Experience

  • Fortune 100 multinational corporation restructures its global tax departmentJones Day advised a Fortune 100 multinational corporation in restructuring its global tax department to optimize compliance with domestic and global reporting requirements and maintain confidentiality for sensitive, privileged materials.
  • Taxpayer obtains full concession from IRS of its characterization of $50 million in proceeds as long-term capital gainOn behalf of a taxpayer, Jones Day obtained full concession from the IRS in a U.S. Tax Court matter affirming the client's position that $50 million in proceeds from litigation funding was properly characterized as long-term capital gain.
  • The following represents experience acquired prior to joining Jones Day.

    Represented and lead trial counsel in U.S. Tax Court case involving large multinational hedge fund advisory firm to determine whether the fund was "engaged in a U.S. trade or business" and was ECI (effectively connected income) as result of its investment activities and whether the fund was subject to withholding under IRS section 1446.

    Represented a multinational corporation during the IRS examination and administrative appeal with respect to the characterization and valuation of intangible assets under IRC section 936 as result of a corporate reorganization and deemed liquidation of the taxpayer into its foreign parent.

    Represented large estate in complex U.S. Tax Court case involving the valuation of an estate comprised of original works of art and the calculation of the appropriate blockage discount.

    Represented a large national accounting firm in a federal grand jury investigation and promoter penalty audit relating to the development, marketing, and reporting of tax shelter transactions; assisted in negotiating a Deferred Prosecution Agreement and an IRS Closing Agreement to resolve both; and assisted in the creation of the company's ongoing compliance and ethics plan.

    Represented a for-profit college and negotiated favorable settlement with IRS of government's disallowance of the client's claimed research and development credits, change in income tax accounting method, and treatment of deferred income.

    Favorably resolved promoter penalty audits, transferee liability assessments, and criminal tax investigations for a corporate client and its more than 60 subsidiaries that had engaged in, and promoted, "Midco" transactions, whereby gain on the sale of assets was sheltered by the sale of loss assets contributed to a corporation.

    Represented employers in worker classification issues and participation in IRS Voluntary Classification Settlement Program.

    Obtained favorable settlement in U.S. Tax Court matter involving transferee liability.

    Represented to CEO of large retailer is dispute with IRS regarding disallowance of passive activity losses and validity of a variable prepaid forward contract.

    Represented vineyard in IRS examination of client's use of a split-dollar life insurance arrangement and participation in an employer welfare benefit plan.

    Successfully litigated complex estate deficiency in U.S. Tax Court involving the disallowance of certain estate deductions and administrative expenses.

  • Speaking Engagements

    • May 15, 2018
      Ethical Considerations for In-House Tax Professionals, Tax Executive Institute
    • December 7, 2017
      Partnership Audits: What Litigators Need to Consider Now, speaker, ABA Seventh Annual National Institute of Tax Controversy
    • December 7, 2017
      Civil Enforcement Priorities, moderator, ABA Seventh Annual National Institute of Tax Controversy

    Speaking Engagements Prior to Jones Day

    June 16, 2017
    Developing A Robust Reasonable Cause Defense, panelist, NYU School of Professional Studies 9th Annual Tax Controversy Forum
    New York, New York

    December 8, 2016
    Speaker, "The New Partnership Audit Rule," ABA Sixth Annual National Institute on Tax Controversy
    Las Vegas, Nevada

    December 9, 2015
    Civil Tax Workshop, panelist, ABA Fifth Annual National Institute on Tax Controversy
    Las Vegas, Nevada

    May 7, 2015
    On the Road Toward Diversity and Inclusion in the Tax Profession, panelist, ABA Section of Taxation

    December 12, 2014
    Where Did the Money Go, and How Will the Government Find It?, panelist, ABA Fourth Annual National Institute on Tax Controversy
    Las Vegas, Nevada

    April 25, 2013
    Anatomy of an International Controversy, speaker, Southeast Michigan Chapter, Tax Executives Institute

    April 18, 2008
    "IRS Audits & Appeals" and "Litigating a Federal Tax Controversy," speaker, Los Angeles Chapter, Tax Executives Institute

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