TEI Detroit Chapter
State & Local Tax Seminar
March 2015
Presenters
Aaron M. Young, Esq.
Partner
p – 212.521.5478
c – 908.507.8107
ayoung@reedsmith.com
Kyle O. Sollie, Esq.
Partner
p – 415.659.5907
p – 215.851.8852
c – 215.499.6171
ksollie@reedsmith.com
Michael J. Wynne, Esq.
Partner
p – 312.207.3894
mwynne@reedsmith.com
Jenny J. Choi, Esq.
Associate
p – 213.457.8186
jchoi@reedsmith.com
New York Tax Updates
March 2015
Corporate Tax Reform Legislation
 Budget Bill – Passed March 31, 2014
 Passed legislature and signed by Governor Cuomo on March 31,
2014
 Generally effective for tax years beginning on or after January 1,
2015
 Main components
 Economic Nexus
 Modified Tax Base
 Classification of Income
 Apportionment
 Combined Reporting
 Net Operating Losses
 New York City – conformity expected soon.
4
Corporate Tax Reform Legislation
 Nexus
 Expanded to include economic nexus standard
 $1M or more of receipts included in numerator of apportionment
factor
 New law aggregates receipts for every company in a combined
group with at least $10,000 of New York receipts
 Nexus established if aggregate New York receipts of at least $1M
 Retains current economic nexus standards for certain credit card
companies
 Greater than 1,000 customers or merchant contracts in New York
 Fulfillment services exception repealed
5
Corporate Tax Reform Legislation
 Nexus
 Creates nexus for companies with no physical presence in New
York, for example (assuming $1M threshold is met):
 Corporations selling digital products primarily used in New York
 Corporations selling services with benefits received in New York
 Corporations receiving interest on loans secured by New York real
property
 Sourcing rules and elections under new law may trigger nexus for
companies historically not subject to tax, for example:
 8% rule for sourcing receipts from certain financial instruments
 Election to source receipts from “qualified financial instruments”
using fixed percentage or based on customer location
6
Corporate Tax Reform Legislation
 Nexus
 Constitutional Issues?
 Potential “Problem” Scenarios
 Out-of-state corporations licensing intangible property used by
customers’ customer in New York
 Out-of-state corporations selling TPP to customers in New York
 Combined group members deemed to have nexus under
aggregation rules because of New York contacts of other members
of the combined group
 Corporate Partner Nexus
 Department may adopt regulations subjecting corporation to tax if
it is a partner of any type of partnership doing business in New
York (or that has economic nexus with New York)
 Subject to challenge
7
Corporate Tax Reform Legislation
 Modified Tax Base
 Article 32 repealed. Banking and financial institutions subject to
tax under Article 9-A
 Tax computed on three bases
 Business income
 Capital
 Fixed dollar minimum
 Separate tax on subsidiary capital eliminated
8
Corporate Tax Reform Legislation
 Modified Tax Base
 New Rates, Caps and Brackets
 Tax rate on entire net income (ENI) base reduced from
7.1% to 6.5% for tax years on or after January 1, 2016
 Lower rate for certain taxpayers (e.g., Qualified Emerging
Technology Companies) and 0% rate for Qualified New
York Manufacturers
 Capital base tax rate of 0.15% phased down to 0% for tax
years beginning on or after January 1, 2021
 Cap under capital base tax increased from $1M to $5M
 Additional brackets under fixed dollar minimum tax
 Current top bracket (receipts > $25M) = $4,500 of tax
 New top bracket (receipts > $1B) = $200,000 of tax
 Phased in reduction of fixed dollar minimum tax for
qualified New York manufacturers and qualified emerging
technology companies
9
Corporate Tax Reform Legislation
 Classification of Income (current law)
 Three categories of capital and income
 Subsidiary
 Investment
 Business
 Entire Net Income
 Includes worldwide income (for non-U.S. corporations, ENI is not
limited to federal taxable income)
 Excludes income, gains and losses from subsidiary capital
 Must add back interest and other expenses attributable to
subsidiary capital and attribute interest/other expenses to
investment income
10
Corporate Tax Reform Legislation
 Classification of Income (new law)
 Three categories of income
 Business Income
 Investment Income
 Other Exempt Income
 Only business income subject to tax
 Business income = ENI minus (i) net investment income and (ii) net
other exempt income
 Repeals exclusion for 100% of income, gains and losses from
subsidiary capital
11
Corporate Tax Reform Legislation
 Classification of Income (new law)
 Starting point for ENI is federal taxable income
 For a taxable alien (non-U.S.) corporation, the starting point for
ENI is effectively connected income
 Must add back treaty benefits
 New law narrows definition of investment capital to investments
in stocks of non-unitary corporations held by the taxpayer for
more than six consecutive months and not held for sale to
customers
 Bonds, debt instruments, other corporate securities and cash no
longer investment income; all treated as business income
 Other exempt income generally = exempt CFC income and exempt
unitary dividends
12
Corporate Tax Reform Legislation
 Classification of Income
 Under new law investment income and other exempt income
must be reduced by interest expenses directly or indirectly
attributable to those items of income
 Attribution no longer required for non-interest expenses
 If interest expense attribution amount exceeds investment income
and other exempt income, the excess interest expense must be
added back to ENI
 New 40% election: In lieu of computing actual interest expenses
attributable to investment income or other exempt income, a
corporation may instead elect to reduce its investment and other
exempt income by 40%
13
Corporate Tax Reform Legislation
 Apportionment
 Single sales factor apportionment formula (MTA surcharge
continues to use 3-factor formula)
 Generally applies market-based sourcing
 Combined Reporting
 Combined report required if corporations
 Are engaged in a unitary business; and
 More-than-50% common ownership test is met (measured
by voting power of capital stock)
 Presence or lack of substantial intercorporate transactions
or distortion is irrelevant
 Alien corporations with ECI included in group. S
Corporations not included. No cross-article combination.
 Affiliated Group Election – If 50% test ownership test met
 Election must be made on original return and is
irrevocable for 7 years. Automatically renewed if not
revoked. If revoked, election not permitted for 3 years
14
Corporate Tax Reform Legislation
 Net Operating Losses
 Equals business loss for the tax year multiplied by apportionment
factor for that year
 Does not include NOLs from tax years beginning before January 1,
2015 (replaced with prior NOL conversation subtraction)
 Removes existing limitation on NOL deductions based on amount
allowed for federal income tax purposes
 Eliminates requirement that NOL deduction originate in the same
source year as the federal NOL deduction for that year
 Conforms NOL carryforward period to the 20-year federal
carryforward period, and permits a three-year carryback (but not
to tax years beginning before January 1, 2015)
15
Corporate Tax Reform Legislation
 Net Operating Losses
 Unabsorbed NOLs generated in tax years beginning before January
1, 2015 cannot be carried forward
 Instead, unabsorbed NOL carryforward amounts existing on the
last day of the taxpayer’s base year are converted into a “prior
NOL conversion subtraction”
 The prior NOL conversion subtraction may be claimed in future tax
years (i) in amount equal to 1/10 of the conversion subtraction
amount over a 20-year period; or (ii) the taxpayer may elect to use
50% in 2015 and 0% in 2016 (with no carryover if unused).
16
Litigation Update
 Retroactive Application of 338(h)(10) sourcing rules
 Caprio v. Dep’t of Taxation and Finance (1st Dep’t 2014)
 Software/Cloud Computing
 Matter of SunGard Securities, ALJ (Feb. 6, 2014)
 Apportionment
 Receipts from Services v. Other Business Receipts
 Expedia, NY DTA (Feb. 5, 2015)
17
Litigation Update
 Royalty Income Exclusion
 Royalties received from foreign related members
 Included in NY ENI
 Decombination
 Focus on loss companies
 SunGard Capital Corp., NY DTA (Apr. 3, 2014)
 IT USA, TAT (Apr. 16, 2014)
 Knowledge Learning Corp, TAT (Sept. 18, 2014)
 Net Operating Losses
 TD Holdings, NY DTA (Jan. 22, 2015)
18
2015 Tax Legislation
 New York City Tax - Conformity Legislation
 Substantially similar to 2015 NYS Corporate Tax Reform
 Single sales factor 2018
 Market sourcing
 Defined economic nexus standard
 Unitary waters-edge combined reporting
 Net operating losses
 New York State Corporate Tax - Corrective
Legislation
 Definition of “qualified financial instrument”
 Definition of “investment capital”
 New York State Budget Finalized March 31, 2015
19
Contact Information
Aaron M. Young, Esq.
p-212.521.5478
c-908.507.8107
ayoung@reedsmith.com
20
Illinois Taxes 2015: At a Crossroads
March 2015
Illinois FY 2015 Budget
22
Illinois Snapshot of 2014 vs. 2015
 New Republican ‘outsider’ Governor, Jan 2015.
 Democratic majorities in House and Senate.
 Income tax rate increases expired 12/31/2014:
 2015 Personal rate: 3.75% (up .75% from 2010, down 1.25% from
2014).
 2015 Corp. rate: 7.75% (up .50% from 2010, down 1.75% from
2014).
 Replacement tax rates remained unchanged.
 If 2015 State spending exceeds $39 Billion, rates drop to
3% and 4.8%, unless Governor declares a Fiscal Emergency.
23
Illinois FY 2016 Budget
24
Illinois FY 2016 Legislative Session Mix
 FY 2015 Budget:
 Booby Trap Budget: full FY Expenses but FY revenues reduced by
25% Jan. 1, 2015.
 FY 2016 Legislative Session:
 FY 2015 Budget Gap Closure - $1.6 billion deficit
 FY 2016 Budget - $6.2 billion deficit
 In play: pending Ill. S. Ct. decision on SB. 1 pension reforms
25
Governor’s Policy Choices
 FY 2015 –
 Expanded Executive authority to sweep special funds
 Tough social spending cuts
 Reduced distributions to local governments
 No new revenues
 FY 2016
 Further pension reforms (legal challenges delay / uncertainty)
 Social spending levels (are FY 2015 cuts a base?)
 New Revenues: eliminate the lapsed tax hike; modernize the sales
tax; freeze property taxes.
26
Illinois Revenues
27
Early Legislative Markers
 Speaker Madigan’s 3% Millionaire Tax
 Requires referendum to approve a constitutional amendment;
would at best bring in $1 B.
 HB 295 – add-back of DPAD; add-back foreign dividend
subtraction; eliminate non-combination rule (diverse factor
unitary members) (SB 717 has same provisions)
 HB 106 – tax on financial transactions at CBOE, CBOT, CME,
and CSE.
 SB 1828 – False Claims Act amendments
 Hang in there for a long overtime session.
28
Illinois Tax Administration
 New IDOR Director Connie Beard,
confirmed.
 Pending Reappointment and confirmation
of James Conway as Tax Tribunal Chief
Judge
 Lisa Madigan, Ill. Atty. Gen. & Steven
Diamond, FCA plaintiff & attorney.
 Chang Wong (Daniel Edelman attorney).
 Regional Transportation Authority?
29
Illinois Income Tax Pressure Points
 Service Income Apportionment / Throw-out
 IDOR legislatively directed to issue “market”
apportionment regulations in 2007 for TYE on or after
12/31/2008
 So far, regulations have been issued for “publishing”, but not
for public utilities, advertising, or general services
 Draft general services regulation has yet to be issued
 Legislative amendments provided specific treatment for
broadcasters
 Audits / Settlements / Cases
30
Illinois Income Tax Pressure Points
Alternative apportionment:
 Section 304(f) for TYE before 12/31/2008 is a standard
UDITPA Sec. 18 (but with Ill. S. Ct. interpretation for “full
apportionment” State policy)
 Effective 1/1/2014, retroactive to TYE on or after
12/31/2008, Section 304(f) is unique in the U.S.
 Alternative apportionment is allowed “if the allocation
and apportionment provisions of [IITA Sec. 304,]
subsections (a) through (e) and of subsection (h) do not,
 “for taxable years ending before December 31, 2008, fairly represent
the extent of a person's business activity in this State,” or,
 “for taxable years ending on or after December 31, 2008, fairly
represent the market for the person's goods, services, or other
sources of business income,”
31
Illinois Income Tax Pressure Points
 Reasons:
 Single Factor / “market” for TYE on
or after 12/31/3008
 Implications:




Throw-out
Throw-back
Other
Full apportionment policy?
 Transportation apportionment
proposed regulations
32
Illinois Income Tax Pressure Points
 Captive Insurance Pending Audits
 Apparently Scioto (Wendy’s) is not final enough, per IDOR
 P.A. 98-978 - Self Procurement Tax eff. 1/1/2015
 S.B. 1573 – introduced to repeal self-procurement tax
 About that NOL suspension that just expired . . .
 Uniformity issues with the 2012 $100,000 limitation?
 2003 and prior NOLs excluded from the suspension?
 What if suspension resulted instead in elimination? Is it a taking?
33
Local Tax Pressure Points
 Local Sales Tax (collected by IDOR) Sourcing


RTA
City of Chicago
 City of Chicago


1 % Use Tax Credit Amendment
Amendment to Ruling No. 5 for Personal Property Lease
Transaction Tax
 Other Municipal Taxes
 Cook County Non-titled Personal Property Use Tax
34
Illinois – Transition Points
 Illinois Supreme Court
 Pension amendments decision
 General Assembly
 After May 31, 2015 a three fourth’s majority is required to
pass legislation. Will new revenue measures surface before
then?
 Tax Tribunal
 Substantive decisions
 Department of Revenue
 Proposed / Pending Regulations
 Settlements / Directors Advisory Group
 City of Chicago
 Mayoral election
 State pension developments
35
Illinois Sales Tax Pressure Points
 False Claims Act Issues
 Nexus
 Shipping Charges
 Wine Gallonage
 Next?
 Consumer Protection Act
Issues
 Shipping Charges
 Discount Coupons
 Next?
36
Contact Information
Michael J. Wynne
p-312.207.3894
mwynne@reedsmith.com
37
Pennsylvania and New Jersey: Income
Tax Developments And Planning
Opportunities
March 2015
Pennsylvania—Sourcing Sales Other Than TPP
 Market sourcing adopted for some receipts for 2014
 Pre-change service / intangible sourcing = your choice
 Statute: Cost of Performance
 Department Position: Customer Location
 DIRECTV litigation
39
Pennsylvania—Market sourcing…sometimes
 What changed?
 Services: Delivery Location
 Leases of TPP: Source to location of first possession by taxpayer
 All other non-TPP sales—COP remains the rule
 Department Informational Bulletin 2014-01
40
Pennsylvania—Market Sourcing Opportunities
 Characterizing Receipts—Services v. Other
 Information services
 Franchise fees
 Characterizing Receipts—Tangible v. Intangible
 Software (See e.g. Dechert)
 Where is a service delivered
 Customer Location v. Customer Benefit
 E.g. Shared services companies
 E.g. Advertising placement
41
Pennsylvania—Licenses to Tangible Personal Property
 License/Lease/Rental to TPP: Only purchaser first obtained
possession in Pennsylvania
 Leased mobile property
 Source to PA, but exclude if leaves PA
 No corresponding position for incoming property
42
Add-Back Comes to Pennsylvania
 Effective for tax years beginning 1/1/15
 Taxes paid credit:



Doesn’t address financial IHCs
“the” principle purpose avoid PA tax?
Reed’s “$1 conduit”
 Taxes paid credit:



Aggregate the other states
Reduce denominator of credit apportionment
Constitutional issues
 Remember: no penalties in PA
43
Pennsylvania Franchise Tax
 Manufacturing and R&D exemptions
 If conducted anywhere, property and payroll factors should be
~0%
 Exempt assets fraction
 Discriminates—only PA companies get to exempt investments in
subsidiaries
 Remedy is a refund
Refund
=
Investment in
Subs
Total Assets
44
44
www.reedsmith.com/statetax
x
Franchise
Tax
Pennsylvania’s Uniformity Requirement
All taxpayers pay same tax rate
Brian Roberts, Comcast CEO
3.07% tax rate
Comcast cable guy
3.07% tax rate
45
PA’s Net Loss Cap
 Cap is the greater of:
 2009: $3m or 15%
 2010-2013: $3m or 20%
 2014: $4m or 25%
 2015: $5m or 30%
 Reed Smith: cap is unconstitutional under uniformity
clause
46
PA’s NOL Cap—Taxpayer Options
 Option #1: Take return position
 No penalties, no compound interest
 “More likely than not” position
 No need to disclose—position is self-evident
 Option #2: Refund claim (Three-year statute of limitations)
 2014 (once filed)
 2013
 2012
 2011
47
What’s Next?
 Pennsylvania’s new Governor
 Former Pennsylvania Secretary of
Revenue
 Budget proposal includes:
 Combined reporting
 Eliminate franchise tax…for real this time
 Sales tax on services
 Increase taxes on banks
 And more…
48
Net Operating Losses
 2002-2005 NOL suspension: statute adds 4 years
to 7 year carryover
 Got federal research credit in 1999-2001? Get 19
year carryover instead of 7
 Foreign dividends = no absorption of NOLs
 Tax benefit rule—gains from sale of depreciated
property
 Post apportionment carryover means NOLs
worth more under single sales fraction
www.reedsmith.com/njtax
49
Reduce Gains with Moroney Basis Adjustments
 NJ mistreats NOLs:
 Historically short carryover
 No carryover unless loss company survives merger
 If your NOLs expired or were lost, increase basis in
property:
 Depreciated during loss years
 Amortized during loss years
 Basis otherwise reduced attributable to losses or
deductions in loss years
 Ford / Toyota win
www.reedsmith.com/njtax
50
New Jersey Apportionment
 Flexibility on sourcing services
 Sales fraction and market sourcing
 To reflect market, consider ultimate destination for sales of TPP
 Dock sales – NJ lacks definitive authority
 Distributor’s warehouse and inventory-in-transit
 Intangibles—domicile or market?
 Gross vs. net for forward contracts
 Property fraction—federal tax basis or GAAP?
 Partnership factors don’t automatically flow up
 NJ has flip-flopped on flow up policy
 Unitary test for partnerships less rigorous than constitutional
standard
www.reedsmith.com/njtax
51
New Jersey – Holding Companies
Jersey
– Holding
Companies
 IHC New
receipts:
source
copyright
and patent royalties
based on use, not licensee’s sales
 Interest addbacks
 Exception for cash sweeps and push-down debt?
 If payor’s NJ factor less than 33%, automatic exception if
interest company files anywhere
 Royalty addbacks
 Refund claims based on unconstitutional discrimination
 Post throwout, make sure IHC has at least some property and
payroll outside NJ
52
BIS LP—Is CBT Now Voluntary?
The BISYS
Group, Inc.
 Limited partnership structure
 Partnership paid tax on behalf
of BIS, which took credit on
CBT return
Taxpayer
 BIS argued non-unitary
and thus no nexus
BISYS, Inc.
BIS LP, Inc.
(“BIS”)
99% Limited
Partner
Partnership
 So far, courts agree that
partner gets refund
1% General
Partner
BISYS
Information
Solutions, L.P.
(“Solutions”)
Doing Business
in New Jersey
www.reedsmith.com/njtax
53
Other Partnership Issues
 Choose apportionment method that’s best
 Flow up partnership income and factors or
 Apportion at partnership level
 No addback of interest and royalties
 Only NJ adjustment to federal taxable income is tax
exempt interest income
 No statutory mechanism for adding back affiliated
expenses incurred by partnerships
 Partnership filing fees
www.reedsmith.com/njtax
54
Contact Information
Kyle O. Sollie
p-415.659.5907
p-215.851.8852
c-215.499.6171
ksollie@reedsmith.com
55
California Issues and Opportunities
March 2015
California Background on Dividend Treatment
 No general DRD
 CRT §25106 elimination if paid out of previously
taxed income
 75% deduction for foreign dividends under CRT §
24411
 But subject to Foreign Investment Interest Offset
57
Opportunity: Reduce FIIO

Attribute to domestic operations

Notwithstanding Regulation § 24344

Apple: taxpayer wins on this issue

More recent trend favors taxpayers:



American General Realty Investment
Appeal of Beneficial
Appeal of Zenith
58
FIIO Impact: Obscured by the Return
59
Opportunity: Factor Representation

25% not deducted is taxed.

SBE is receptive to factor representation.
Argonaut Group. CRT § 25137
60
Include prop., payroll, sales of dividend paying sub. for each
year from which E&P was paid.
______________________________
61
R&D Credit: Alternative Calculation
 Alternative incremental credit
 Different fixed base and qualified research %
 CA conforms to IRC
62
Special Tax Base Issues
63
Income From “Excess Cash” – Formula
December
January
February
March
April
May
June
July
August
September
October
November
December
Cash
Balance
$90.00
$100.00
$90.00
$75.00
$85.00
$110.00
$105.00
$95.00
$90.00
$85.00
$100.00
$110.00
$130.00
Cash Surplus
Income From
(Deficit)
Cash
$10.00
$0.50
-$10.00
$0.45
-$15.00
$0.38
$10.00
$0.43
$25.00
$0.55
-$5.00
$0.53
-$10.00
$0.48
-$5.00
$0.45
-$5.00
$0.43
$15.00
$0.50
$10.00
$0.55
$20.00
$0.65
Total $
5.88
Top deficit month
Plus 20%
As increased by 20% margin
Average monthly balance
Business Income Percentage
Income from cash for year
Business income
$15.00
$3.00
$18.00
÷$97.92
=18.38%
x$5.88
=$1.08
NBI
$4.80
Month w/
greatest
deficit
÷
64
COD Income / One-Time Settlement
65
Tenneco West comparison
 Tenneco West sold properties on an installment-sale
basis
 At the time of many of the sales, its California
apportionment was nearly 90%
 When Tenneco West recognized the income, its California
apportionment had dropped to 10%
66
EZ Credits
 Take-aways:
 Compute credit limitations on a group-wide, not entityby-entity basis
 Compute credit limitations as if all the enterprise zones
were one single zone
 Take a deduction for interest as if the entire United
States is an enterprise zone
67
EZ limits: loosen calculation of limits
 Whole unitary group should be considered the
“taxpayer”


Definitions under 23622.7
In apportionment context “taxpayer” means the group:
see Finnigan
 All zones should be treated as a single “zone”


A “credit” against “the tax”
Legislative history: “one strong, combined, business
friendly incentive program”
68
California NOL
Extensions
 Four more years!
Last Carryover Year
 Legal Ruling 2011-04
 Ruling: 4-year extension requires
income in suspension year
 That requirement
is not in the statute
69
Per Reed
Loss Year Per FTB
Smith
2000
2010
2016
2001
2011
2017
2002
2012
2017
2003
2013
2017
2004
2014
2018
2005
2015
2019
2006
2016
2020
2007
2017
2021
2008
2028
2031
2009
2029
2031
2010
2030
2031
Rule
10+2+4
10+2+4
10+1+4
10+4
10+4
10+4
10+4
10+4
20+3
20+2
20+1
Opportunities from Form 4797 Gain
 Taxpayers who should be interested:

Disposed of property / otherwise recognized federal
gain in NOL suspension years 2008-2011; or

Disposed of property placed in service during the
period 1987-2004 and you had NOLs for a year when
the property was in service
70
Opportunities from Form 4797 Gain - Example
1990:
$45 Million Property
Depreciate Straight-Line Method
1990–2009:
Loss Years
2010:
$25 Million Adjusted Basis in Property
Sell Property for $45 Million
Problem:
Fictional $20 Million Gain
Solution:
Basis Adjustment of $20 Million
71
Contact Information
Kyle O. Sollie
p-415.659.5907
p-215.851.8852
c-215.499.6171
ksollie@reedsmith.com
Jenny J. Choi
p-213.457.8168
jchoi@reedsmith.com
72
Reed Smith LLP – State Tax Practice
Chicago ▪ Los Angeles ▪ New York
Philadelphia ▪ San Francisco ▪ Washington, D.C.
Lee A. Zoeller
Philadelphia
215 851 8850
Cell: 610 246 8815
lzoeller@reedsmith.com
Adam P. Beckerink
Chicago
312 207 6528
abeckerink@reedsmith.com
Brent K. Beissel
Philadelphia
215 851 8869
bbeissel@reedsmith.com
Stephen J. Blazick
Philadelphia
215 851 8877
sblazick@reedsmith.com
Jenny J. Choi
Los Angeles
213 457 8186
jchoi@reedsmith.com
Marty H. Dakessian
Los Angeles
213 457 8310
mdakessian@reedsmith.com
Daniel M. Dixon
Philadelphia
215 851 8854
ddixon@reedsmith.com
Frank J. Gallo
Philadelphia
215 851 8860
Cell: 215 805 6008
fgallo@reedsmith.com
Jennifer S. Goldstein
New York
212 521 5406
jsgoldstein@reedsmith.com
David J. Gutowski
Philadelphia
215 851 8874
Cell: 610 368 0813
dgutowski@reedsmith.com
Christine M. Hanhausen
Philadelphia
215 851 8865
chanhausen@reedsmith.com
Michael A. Jacobs
Philadelphia
215 851 8868
mjacobs@reedsmith.com
Kenneth R. Levine
Philadelphia
215 851 8870
klevine@reedsmith.com
Sara A. Lima
Philadelphia
215 851 8872
slima@reedsmith.com
Michael I. Lurie
Philadelphia
215 241 5687
mlurie@reedsmith.com
Erin J. Mariano
San Francisco
415 659 4750
emariano@reedsmith.com
Paul E. Melniczak
Philadelphia
215 851 8853
pmelniczak@reedsmith.com
Kelley C. Miller
Philadelphia
215 851 8855
kmiller@reedsmith.com
Alexandra E. Sampson
Washington, D.C.
202 414 9486
asampson@reedsmith.com
Mike Shaikh
Los Angeles
213 457 8044
mshaikh@reedsmith.com
Kyle O. Sollie
Philadelphia
215 851 8852
ksollie@reedsmith.com
Brian W. Toman
San Francisco
415 659 5994
btoman@reedsmith.com
Jack Trachtenberg
New York
212 521 5414
jtrachtenberg@reedsmith.com
Jennifer C. Waryjas
Chicago
312 207 6470
jwaryjas@reedsmith.com
Shirley J. Wei
Los Angeles
213 457 8217
swei@reedsmith.com
Robert E. Weyman
Philadelphia
215 851 8160
rweyman@reedsmith.com
Aaron M. Young
New York
212 521 5478
ayoung@reedsmith.com
Gordon Yu
Philadelphia
215 851 8876
gyu@reedsmith.com
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