Steve helps clients prevent and resolve tax problems throughout their life cycle, starting with tax planning, compliance, financial statement implication analysis, audit defense and litigation, legislative monitoring and advocacy, and the formation and leadership of taxpayer coalitions. Steve developed many of these techniques as a litigator for the US Department of Justice, Tax Division, as chief counsel for the District of Columbia’s Office of Tax and Revenue, and further refined them during his tenure as general counsel for the Council on State Taxation (COST).

Steve practices at the forefront of state and local tax issues, including developments in the world of cloud computing, artificial intelligence such as ChatGPT and digital goods and services. He helps clients understand tax threats and opportunities, and develop holistic solutions, no matter the tax issues or jurisdiction. He also brings this same skill set to the highly challenging world of unclaimed property.

Steve represents Fortune 100 companies in litigation while working to address the larger tax policy questions through state legislatures, the US Congress, the National Conference of State Legislatures, the National Governors Association, the Multistate Tax Commission and the Streamlined Sales Tax Governing Board. His background has taught him that standalone litigation is not always the most efficient manner of solving a tax problem or preventing its spread – thus, he often works to address problems by taking advantage of tax policy points of entry offered by state and local governments.

Steve has authored articles for professional publications, speaks at national conferences and is interviewed frequently by journalists covering state and local tax developments. He has appeared before the US House Judiciary Committee as an expert on alternative approaches to the Internet Sales Tax issues, and in a similar capacity before other government agencies. Steve serves as outside counsel on state tax and unclaimed property matters for the Entertainment Software Association, the National Retail Federation, the Retail Industry Leaders Association and CompTIA.

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• On behalf of a coalition of Fortune 50 clients, spearheaded termination of a controversial Uniform Law Commission, Uniform Division of Income for Tax Purposes Act (UDITPA) revision project
• On behalf of Shell Oil Company, ExxonMobil Oil Corporation and Hess Corporation, obtained a ruling of first impression that non-mutual collateral estoppel applied to the District’s taxing authority
• On behalf of Sunbelt Beverage Company, LLC, won a case at the DC Court of Appeals holding that a standard statute of limitation applies, limiting an audit even if the tax payer filed the wrong return
• On behalf of a coalition, routinely works to block legislation seeking to impose sales tax on digital goods, and advances legislation providing exemption from tax for such goods and services
• On behalf of a Firm client, won a case asserting a taxpayer’s right to flow-up factors from pass-through entities in calculating DC taxable income
• Successfully supported adoption of a resolution by the National Conference of State Legislatures opposing state use of auditors paid on a contingent fee basis

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