Michael Scarduzio focuses his practice on federal and state and local tax (SALT) controversies, tax litigation, and criminal tax matters. He has represented taxpayers at all phases of a tax controversy, from audit through litigation, including novel issues of first impression such as the U.S. tax implications of a foreign master-feeder fund's investment activities and issues arising under I.R.C. § 7212(a).
Michael has substantive experience handling a variety of complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), reportable transactions, transfer pricing, debt-equity classifications, foreign tax credits, and excise tax on reinsurers.
Michael has written and spoken on tax-related subjects. He is a member of the American Bar Association (Tax Section) and the New York City Bar Association (Personal Income Tax Committee). He also is a volunteer with the New York County Lawyers' Association Tax Court Calendar Pro Bono Program.
The following represents experience acquired prior to joining Jones Day.
Tax Controversy and Tax Litigation
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.
Tax Controversy May Arise for Those Claiming Relief Under the FFCRA and CARES Act, Journal of Tax Practice & Procedure
Publications Prior to Jones Day
Key Provisions of the Proposed Partnership Audit Regulations, coauthor, Journal of Tax Practice & Procedure
Turning the Tide: The US Addresses Its Role as a Tax Haven, coauthor, The Champion
The Repeal of the TEFRA Audit Regime and the Shift from an Aggregate to an Entity-Level Approach to Partnership Taxation, coauthor, Journal of Tax Practice & Procedure
- September 22, 2021
Administrative Practice and Court Procedure & Practice Joint Session: Current Developments, co-moderator
- May 17, 2021
Important Developments, moderator, 2021 ABA Tax Section Administrative Practice Committee
- September 26, 2019
The Role of Hardship in Tax and Tax Controversies
- October 20, 2017
Conflicts for Tax Professionals, New York County Lawyers’ Association
Speaking Engagements Prior to Jones Day
Tax Court 101: The Battle of the Experts, panelist, ABA Section of Taxation Meeting
Ethics for the Tax Professional, panelist New York County Lawyers’ Association
- New York University (LL.M. in Taxation 2014); Rutgers University (J.D. magna cum laude 2012; Editorial Board Member, Rutgers Journal of Law & Public Policy; Dean's Scholar [awarded to top 5% of class]); Marist College (B.A. in Political Science cum laude, December 2008)
- New York, New Jersey, U.S. District Court for the Southern District of New York, and United States Tax Court
- Extern, Internal Revenue Service, Office of Chief Counsel, Large Business and International Division, New York (January-May 2014)
Legal 500 United States (2021): Rising Star in the area of Tax: US taxes: contentious
- Law Clerk to Judge Karen L. Hayes, U.S. District Court, Western District of Louisiana (2012-2013); Intern to Judge Dolores K. Sloviter, U.S. Court of Appeals, Third Circuit (January-April 2012)