Project Sales

JASON T. BELL

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TAX ATTORNEY

EXECUTIVE SUMMARY

Tax Consulting ~ Regulatory Tax Compliance ~ FIN 48 ~ Federal & State Tax Litigation

Federal & State Tax Audits ~ Mergers & Acquisitions ~ Due Diligence ~ Negotiations ~ Strategic Tax

Planning ~ Research & Planning ~ Client Relationship Management ~ Team Leadership

Accomplished and ethical Tax Attorney with expertise in driving change through organizations by reducing tax budget

and potential company liability, while ensuring that clients remain in compliance with all laws and regulations.

Demonstrated talent in analyzing Federal and State tax audits, drafting protests letters, litigating cases, and negotiating

settlements that reduced state taxes by up to $2,000,000. Superior proficiency in developing tactical plans and strategies.

Dynamic record of top performance in managing teams that achieve aggressive goals. Demonstrated ability to manage

multiple projects simultaneously. Proven track record in all areas of US Federal and State tax planning.

RECENT EMPLOYMENT HISTORY

DELOITTE TAX LLP, Charlotte, NC 2007 – Present

A Big Four Public Accounting Firm.

Tax Manager (2008 – Present)

Tax Senior (2007 – 2008)

Oversee multiple tax planning, tax consulting, and tax compliance projects. Provide direction and manage up to six staff

members on projects. Collaborate with clients to analyze business needs and discuss products and services. Assist in the

negotiation of fees and terms of the engagement. Handle the preparation of information document requests and

coordinate with clients on responses and issues. Perform all scheduling functions for staff in order to meet project

deadlines. Report all issues and project status to Tax Partner.

Key Achievements:

Managed a complex tax planning and tax modeling project for a Fortune 500 manufacturer emerging from

bankruptcy. Project included managing staff on the preparation of a state tax model to analyze several restructuring

options that allowed the client to assess the tax impact of the restructuring under various scenarios. Collaborated with

colleagues on the federal consolidated tax attribute reduction and tax basis modeling.

Spearheaded the development of an automated workbook for a Fortune 500 pipeline company that analyzed fixed

asset data and computed state tax credits on qualifying assets. The workbook enabled the company to identify

potential credit benefit and model alternative scenarios for the issues identified. Project resulted in more than

$31,000,000 in state credits for the client.

Managed a complex Internal Revenue Code Section 382 study analyzing the client’s state net operating losses for five

filing groups and 37 states. The study was completed under a tight deadline of only 10 days in anticipation of the

client’s annual report filing.

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Partnered with the firm’s Atlanta office to successfully manage a state RAR reporting project for a Fortune 100

retailer. The project involved preparing and filing more than 230 state and local tax return filings under tight

deadlines. Increased the project’s efficiency by assuming the lead role in utilizing the firm’s technology to work

virtually across multiple offices.

Developed an apportionment workbook for a REIT state tax compliance project with more than 100 state tax return

filings. The workbook analyzed the client’s apportionment data and sales of real property through multiple tiers of

flow through entities. The workbook enabled the project team to organize a large volume of data, which increased the

project’s efficiency. Project was delivered at 10% under budget.

Reduced state tax audit assessment by more than $2,000,000 for a Fortune 500 home builder by filing an

administrative appeal to protest the state’s final audit determination. Project included managing staff on the research

of audit issues, drafting the protest letter, and modeling settlement scenarios that allowed the client to assess the

strength and weaknesses of its positions.

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DEFRANCESCHI & KLEMM, P.C., Boston, MA 2000 – 2007

Tax boutique law firm providing legal services to clients, including tax representation, estate planning, and business

consulting.

Tax Attorney

Represented clients at a five attorney law firm with an emphasis on Federal and State Tax Controversies. Prepared and

drafted United States Tax Court petitions, United States District Court pleadings, United States Appellate Court briefs,

and state court pleadings. Represented clients during all phases of litigation, including settlement conferences, motions,

trial proceedings, and briefs. Represented clients during Federal and State tax collection proceedings, which included

offers in compromise, installment agreements, collection due process hearings, and bankruptcy proceedings.

Key Achievements:

Represented a bankruptcy estate in a sales tax dispute with the Massachusetts Department of Revenue before the

United States Third Circuit Court of Appeals. Assumed the lead role in drafting the appellate brief. The United States

Third Circuit Court of Appeals affirmed the lower court’s decision, disallowing the Massachusetts Department of

Revenue’s claim against the bankruptcy estate. Saved the bankruptcy estate more than $2,000,000 in sales tax as a

result of efforts.

Successfully filed an Internal Revenue Code Section 7430 Qualified Offer as part of the litigation proceedings before

the United States Tax Court. Assumed the lead role in drafting the application and related motions for litigation costs.

Recouped significant litigation costs and fees for the client as the prevailing party in the underlying litigation.

BRICKLY, SEARS, & SORETT, P.A., Boston, MA 1999 – 2000

A litigation defense law firm specializing in the representation of public utility companies.

Law Clerk

Drafted motions, answered complaints, reviewed depositions, and created indexes for depositions. Researched various

legal issues and drafted memoranda with recommendations.

EDUCATION

LL.M. in Taxation, Boston University School of Law, Graduate Tax Program, Boston, MA

Juris Doctor, New England School of Law, Boston, MA

Dean’s List

New England Law Review

Published Law Review Article Bankers Life & Casualty Co. v. United States: Using a Balanced Approach to

Review a Treasury Regulation Issued Pursuant to the Commissioner’s General Authority, New England Law

Review, v. 34, no. 2

Won the Law Review award for Best Proofreader

National Tax Moot Court, St. Petersburg, FL

New England School of Law Honors Moot Court

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Bachelor of Arts, Marine Affairs, University of Rhode Island, Kingston, RI

Dean’s List

CERTIFICATIONS

Admitted, Massachusetts Bar

Admitted, United States Tax Court

Admitted, United States District Court for the District of Massachusetts

Admitted, United States First Circuit Court of Appeal

Admitted, United States Third Circuit Court of Appeals

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TRAINING

Ethics Training ~ FAS 109: Accounting for Income Taxes

State Treatment of Pass Through Entities ~ Mergers & Acquisitions: State Issues

Unusual State Tax Regimes ~ State Addback Provisions & Other Adjustments

Due Diligence: State Issues and Considerations ~ Multinational Groups

State Credits & Incentives: Technical Issues ~ Tax Shelters & State Adjustment Powers

Advanced Allocation & Apportionment ~ State Tax Controversies ~ Hot Topics: Sales and Use Tax

State Tax Implications of Financially Distressed Companies

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