Lawyer Bio : L. Neill Edwards

Over the last (nearly 20) years in tax practice, Neill Edwards has amassed extensive experience in multistate and local tax planning, controversy, and related regulatory work on a national level as well as in multistate economic development matters. This experience covers all fifty states, and virtually all categories of taxes and related state regulatory imposts.

He serves blue chip and other major clients in virtually all industry sectors, including financial services and securities, automotive services, manufacturers, insurance companies, telecommunications companies and utilities, technology, media and other intellectual property companies, marketing companies, investment/acquisition companies, franchises, wholesalers and retailers, real estate development and investment, transportation, outsourcing, logistics, consulting, aviation and hospitality concerns.

In addition to more traditional C corporation, S corporation, LLC, and individual tax work, he has amassed tax planning and controversy experience with various hybrid entities, such as REITs, REMICs, SMLLCs, Series LLCs, QSubs, "tax planning" check-the-box electing entities, various types of holding companies and special purpose entities, and statutory, business, and other trusts (including asset titling, unit, and syndicated trusts).

He has successfully worked on numerous complex matters of “first impression” in various tax jurisdictions. He has negotiated and documented several billion dollars’ worth of state and local grants, credits, abatements, and related incentives in various states.

Representative state and local tax offerings cover more traditional planning and controversy work in the income, franchise, sales and use, property, unemployment, telecommunications, insurance, banking, and excise tax areas, and unclaimed property/escheat matters. This work includes audit preparation, management, and defense, administrative and post-administrative appeals, nexus and reverse nexus work, sourcing planning, special entity work, affiliate and attributional tax planning, “Amazon” tax/representational nexus, multistate supply chain, multistate combined (for separate jurisdictions) and consolidated issues, characterization and recharacterization work (including unitary, addback, and "§ 482" planning), transaction sourcing, etc., as well as the state and local tax implications of international entities and cross-border transactions. He also has extensive experience in less traditional offerings such as voluntary disclosure vs. amnesty, offers in compromise, managed audits, ruling requests, and multidisciplinary, multistate choice of law, reorganizational, and legislative and regulatory solutions. He has also written briefs to the U.S. and state Supreme Courts on tax and tax-related constitutional issues.