Jeffrey P.
Birdsong
- Position
- Partner
- Office
- New Orleans
Jeff Birdsong is a partner in the Tax Practice Group, where he represents businesses on state and local tax matters and not-for-profits in all areas of tax compliance.
Jeff advises businesses from across the industry spectrum on the full range of state and local tax (SALT) issues, including corporate income, franchise, sales and use, property, severance, hotel/motel, and other taxes. He also offers guidance, conducts SALT-related due diligence, provides post-closing support in the context of corporate transactions, and counsels not-for-profits on the formation of tax-exempt entities, tax reporting, and compliance.
Jeff works with clients at every step in the process, routinely developing effective tax strategies regarding commencing operations in Louisiana, property tax reporting, a wide variety of sales and use tax exemptions and exclusions, intercompany and related-party transactions, transfer pricing, inventory tax credit, multistate tax exposure for income tax withholding, Public Law 86-272, tax incentives, the constitutional limitations on the power to tax, and other matters. He frequently provides in-house training and presentations to clients and professional groups on a range of emerging tax issues.
In his tax controversy practice, Jeff delivers effective counsel in disputes with SALT authorities. He regularly advises clients in audits, protests, and appeals; appears before administrative bodies; and represents clients in mediations and settlement discussions. Jeff frequently helps clients reduce tax exposure and mitigate penalties through voluntary disclosures and negotiation of favorable settlements.
Among recent matters, Jeff was a member of the trial team that successfully argued before the Louisiana Supreme Court that Act 109, which limited the availability of the individual income tax credit for taxes paid to other states, violated the dormant Commerce Clause of the US Constitution. He also helped develop winning arguments in a SALT case that changed the long-held general consensus on the application of late payment penalties, prompting a legislative response.
In his work with not-for-profits and tax-exempt organizations, Jeff works to obtain tax exemptions, structure internal governance systems, account for and mitigate unrelated business taxable income, evaluate and structure new programming based on its effect on continued eligibility for tax-exempt status, and receive and protect property tax exemptions, among other activities. He has worked with traditional charitable, educational, healthcare, scientific, and religious organizations on unique issues affecting each type of entity as well as private foundations and supporting organizations in furtherance of his clients' goals. Jeff has also provided counsel on complex related-party tax-exempt structures, including developing and implementing the reorganization of a tax-exempt healthcare organization into a network of related entities.
A lifelong fan of live music, Jeff is committed to the future of New Orleans and serves on the boards of several organizations that seek to promote the capacity of musicians, preserve the civic fiber of New Orleans, and bridge the digital divide.