Frank J.Jackson

The following represents experience acquired prior to joining Jones Day.

Successfully quashed a series of summonses served on U.S. financial institutions pursuant to the United States-Russian tax treaty and at the request of the Russian Federation.

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.