Sullivan
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Sullivan represents clients in conflicts with the Internal Revenue Service and state tax authorities, and we are particularly recognized as a leader at resolving Massachusetts state tax controversies for both individuals and businesses.

We manage all stages of tax disputes, including audits, administrative appeals and litigation. When the stakes are large and the law is unclear, we obtain private rulings from the Internal Revenue Service and state tax authorities for our clients.

Recent Successes

Client Work

  • Partnership tax dispute before the U.S. Tax Court concerning the "at risk" rules and a single-member LLC
  • S corporation tax dispute before the U.S. Tax Court concerning debt basis and other issues
  • State income tax disputes of all sorts, including those concerning income apportionment, business purpose and economic substance
  • Disputes concerning state addback statutes and the deductibility of royalty and interest expenses
  • Qualification and defense of manufacturing corporations, research and development corporations and security corporations
  • State sales and use tax disputes, including manufacturer-vendor disputes, and disputes concerning use tax collection obligations
  • Domicile planning, audit defense and litigation for high-net-worth individuals (HNWI)
  • Disputes relating to administrative summonses issued by federal and state tax authorities, including third-party summonses
  • Discovery disputes related to attorney-client privilege and the work product doctrine
  • Disputes concerning the Massachusetts room occupancy excise, including the taxation of frequent guest programs and the nature of hotels subject to the excise
  • Disputes concerning the Massachusetts convention center surcharge as it applies to private charters and whale watch cruises
  • Responses to federal and state tax collection activities, including liens and levies
  • Voluntary disclosure agreements (VDAs) for non-filers
  • Advice concerning the filing of amended tax returns
  • Cooperation with our Government Investigations & White Collar Defense Group in potentially criminal tax matters
  • Pro bono representation in cutting-edge tax matters, such as the scope of medical expense deductions for a patient suffering from gender identity disorder
Viewpoints
All Viewpoints
How I Made Partner: 'Prioritize What Is Important to You, Do What Energizes You,' Says Sarah Wellings of Sullivan & Worcester
Sarah Wellings was profiled in the article "How I Made Partner: 'Prioritize What Is Important to You, Do What Energizes You,' Says Sarah Wellings of Sullivan & Worcester," published by Law.com [sub. req'd] as part of their “How I Made It Q&A Series." In the Q&A, Sarah addresses a range of topics related to her professional development as a lawyer, from her previous years as an associate at Sullivan to going in-house for 11 years, and her return to Sullivan and becoming a partner in January 2024. She reflects on the challenges faced along her career path and offers advice and insight about the keys to successful business development for herself and other lawyers. "Make sure you prioritize what is important to you and do what energizes you. This will help you avoid burn out and open doors that help advance your career in ways you never expect," she says.
Part 2: The Impact of Massachusetts Court Cases on State and Local Tax Policies
Richard Jones was featured in an episode of the SALTovation podcast titled "The Impact of Massachusetts Court Cases on State and Local Tax Policies," published on January 23, 2024. In the episode, part two of a two-part series, Rich continues the discussion with SALTovation on recent landmark cases and their implications on tax policies and practices. They discuss two important state and local tax cases: Akamai and Bass Holdings. They delve into the complexities of determining whether a company is selling software or services, and the taxation implications. They also explore the concept of unitary business and its impact on apportionment. In this episode, Rich provides valuable insights into the nuances of these cases and offers advice on navigating state and local tax issues. Topics discussed in this episode: The pronunciation and role of Akamai in the technology and tax world, exemplify the challenges in classifying software versus services within taxation. The significance of the unitary business principle in SALT litigation and its application in recent tax cases, specifically referenced in the 'Vas Holdings' debate. An explanation of how court decisions can overturn long-standing tax policies, offering a fresh perspective on statutory interpretations and SALT applications. Richard’s experiences in the courtroom, shed light on the strategies used in SALT litigation to secure favorable outcomes. The encouragement to question accepted tax policies and insights into the pendulum of taxpayer victories in recent SALT litigation. Listen to the episode »
Sullivan & Worcester Attorneys Named to the 2026 Lawdragon 500 Leading Global Tax Lawyers Guide
Boston, MA – Sullivan & Worcester announced that David Nagle, Ameek Ashok Ponda and Richard Jones were selected for inclusion in the 2026 Lawdragon 500 Leading Global Tax Lawyers guide. The guide recognizes attorneys for exceptional work in handling tax aspects of transactional matters, complex tax disputes and litigation, and advising private wealth clients and family offices.  Dave is managing partner of Sullivan. He represents companies in tax disputes before the Massachusetts Department of Revenue and the Internal Revenue Service. He also advises companies and individuals in tax audits, administrative appeals, and litigation and state tax issues related to transactions. His recent professional honors include Best Lawyers’ Boston Litigation and Controversy - Tax Law Lawyer of the Year, Boston Magazine Top Lawyers in Tax and International Tax Review’s World Tax Guide. Ameek advises clients on domestic and international taxation matters, with a focus on mergers and acquisitions and real estate investment trusts (REITs). He is nationally recognized for his work in REIT conversions and cross-border matters across a broad range of property sectors. He has received numerous industry honors, including Forbes America's Best-In-State Tax Lawyers, Boston Magazine Top Lawyers in Tax Law and was ranked by Chambers USA as a Recognized Practitioner in Tax (2006-2026) and REITs: Tax (2013-2026). Rich handles state and local tax litigation for companies in a wide range of industries and transactional planning related to corporate, personal income and sales tax matters. A skilled litigator, he has a successful track record of recent landmark victories in tax cases before the Massachusetts Supreme Judicial Court. He has received numerous professional awards, including Massachusetts Lawyers Weekly Go To Tax Lawyer in 2026 and Boston Magazine Top Lawyers in Tax Law, and was ranked by Chambers USA in Tax. About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.
Top Tier Firm, Legal 500 United States 2026
Sullivan & Worcester Ranked in the Legal 500 United States 2026 Edition
Boston, MA – Sullivan & Worcester announced that its practice groups and attorneys have been ranked and recommended in the Legal 500 United States 2026. The firm’s Real Estate practice was newly ranked Tier 1 in the “Real estate – mid-market ($0-500m)” category and the firm maintained rankings across a variety of practice areas. Partners Nicole Crum and John Steiner were newly ranked as Leading Partners and Ryan Rosenblatt as a Next Generation Partner. Peers and more than 300,000 corporate counsel were surveyed and interviewed globally in the past 12 months to assess law firms’ overall visibility and reputation, culminating in detailed rankings and editorial. The Legal 500 is an independent guide, and firms and individuals are recommended purely on merit. Sullivan's lawyers received the following rankings: Leading Partners: The Legal 500’s Guide to Outstanding Lawyers Nationwide Benjamin Armour - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) Ameek Ashok Ponda - Real Estate Investment Trusts (REITs)  Nicole Crum - Mutual/registered/exchange-traded funds Lewis Segall - M&A: Middle-Market (Sub-$500m); M&A: middle-market ($0-250m) John Steiner - Real estate – mid-market ($0-500m) Douglas Stransky - International Tax Joel Telpner - Fintech Next Generation Partners: The Legal 500’s Guide to Up-and-Coming Lawyers Nationwide Ryan Rosenblatt - General commercial disputes – mid-market ($250-500m) Sarah Wellings - Real Estate Investment Trusts (REITs) Practice Areas Ranked and Attorneys Recognized Corporate Governance “Our lead partner, Nicole Crum, who leads the investment industry practice, is exceptional. She demonstrates strong industry knowledge yet is very personable and anticipates what we need to know or what we should consider doing to handle any matter. The team roll up their sleeves and provide recommendations as to how we as a board should handle any matter. Strong service commitment and work ethic!” “The team we have at Sullivan & Worcester has served our company for years and knows the management team, staff as well as our board members. They are extremely responsive and proactive and anticipate what we should be aware of, concerned about, excited about, and how to handle oversight, processes and protocols to ensure we are carrying out our fiduciary duties. The partners are experts in this industry.” Leading Partner: Nicole Crum Recommended Lawyers: Howard Berkenblit, David Leahy Dispute Resolution/General Commercial Disputes “Diverse skillset. Client centric. Transparency. Urgency provided on all matters.” “I have worked with Gerry Silver for over 15 years and have found his pragmatic approach to complex matters refreshing. He understands our business, culture and market, and will give me his opinion in a digestible manner.” Next Generation Partner: Ryan Rosenblatt Recommended Lawyers: Gerry Silver, Patrick Dinardo, Laura Steinberg, Michael Sullivan, Amy Zuccarello, Erika Todd, Christopher Shields, Anna Lea McNerney Employee Benefits, Executive Compensation and Retirement Plans: Design “The level of expertise is top shelf. David Guadagnoli seems to know all of ERISA and IRS rulings.” “David Guadagnoli and Amy Sheridan both have superior knowledge in their respective areas. I value the ability to raise issues whether simple or complex. The firm takes the same diligent approach across all spectrums of complexity.” Recommended Lawyers: David Guadagnoli, Amy Sheridan Environment: Transactional Fintech “Sullivan & Worcester is one of the finest firms with which I have worked.” “The lawyers are excellent, and the firm consistently provides the highest quality of customer service.” Leading Partner: Joel Telpner Recommended Lawyers: Natalie Lederman, Benjamin Armour, Scott Kaufman, Harvey Bines, Christopher Curtis Land Use/Zoning Recommended Lawyers: Gregory Sampson, Ashley Brooks, Victor Baltera, Karen Kepler, Ashley Tan M&A: Corporate and Commercial: Venture Capital and Emerging Companies Recommended Lawyers: Scott Kaufman, Lewis Segall, Benjamin Armour, Michael Student M&A: Middle-Market ($0-250m) “The partner Lewis Segall has been working with our company for 15 years and we have a good working relationship with him. He knows our history and very attentive to our needs.” “Lewis Segall is very attentive to our needs. We very much value him.” Leading Partners: Benjamin Armour, Lewis Segall Recommended Lawyers: Natalie Lederman Mutual/Registered/Exchange-Traded Funds “Sullivan & Worcester's practice is defined by its deep expertise in investment funds and its ability to deliver clear, commercially grounded advice across the full fund lifecycle—from formation and structuring to regulatory compliance and complex transactions.” “The team is highly experienced, collaborative, and excel in efficient execution and clear communication.” Leading Partner: Nicole Crum Recommended Lawyers: David Leahy, David Mahaffey, Rachael Schwartz Real Estate Leading Partner: John Steiner Recommended Lawyers: Ashley Brooks, Karen Kepler, Gregory Sampson, Sharon Leifer, Louis Monti, Spencer Stone, Ashley Tan Real Estate Investment Trusts (REITs) “We have built multiple complex and sophisticated REIT platforms over the years and worked with many top-tier REIT specialists, but Sullivan’s REIT practice is by far the best, with Sarah Wellings.” Leading Partner: Ameek Ashok Ponda Next Generation Partner: Sarah Wellings Recommended Lawyers: Angela Gomes, Louis Monti, Shu Wei, Cameron Cosby International Tax “The international collaboration with S&W is exceptional.” “What really stands out is their willingness to engage, openness to different ideas and opinions, clearly expressed expectations, and clients' objectives.” Leading Partner: Douglas Stransky Recommended Lawyers: Lewis Greenwald, Eric Rietveld Tax > US Taxes: Contentious Recommended Lawyers: Richard Jones, David Nagle, Daniel Ryan, Caroline Kupiec Tax > US Taxes: Non-Contentious “Sarah Wellings is, quite simply, the best lawyer we have ever worked with. Her expertise extends far beyond tax and REIT matters, encompassing governance, financing, and complex commercial issues. Decades of experience and technical mastery make her an indispensable partner. Sarah is our central point of contact who makes everything seamless. Her in-house counsel background gives her a unique client perspective: she anticipates needs, solves problems before they arise, and delivers concise, well-structured updates that simplify even the most intricate issues. She coordinates effortlessly with all parties involved. Her judgment is exceptional. Sarah strikes the perfect balance between comprehensive academic rigor and practical, business-oriented advice. She combines technical REIT/tax excellence with commercial instincts, ensuring every recommendation is both legally sound and strategically smart. Her ability to translate complex law into clear, actionable guidance is unmatched. Sarah is incredibly responsive without ever sacrificing quality. She treats our matters as her own, demonstrating a rare ownership mindset and collaborative spirit. Her integrity is uncompromising, giving us absolute confidence in her counsel. In short, Sarah Wellings defines legal excellence: reliable, commercially minded, and client-focused. Working with her feels like being in the safest possible hands; she consistently exceeds expectations and orchestrates complex transactions with clarity and precision.” Recommended Lawyers: Ameek Ashok Ponda, Richard Jones, Douglas Stransky, Sarah Wellings About Sullivan Sullivan & Worcester (Sullivan) is a premier international law firm with lawyers in Boston, London, New York, Tel Aviv and Washington, D.C. Sullivan’s clients, including Fortune 500 companies, leading financial services firms and asset managers, boards of directors, real estate companies, and emerging businesses, rely on Sullivan’s ability to navigate complex legal and operational landscapes, the impeccable judgment of its lawyers, and its commitment to best-in-class client service.

Tax Controversies & Litigation

Tax Controversies & Litigation

Tax Controversies & Litigation

Tax Controversies & Litigation