Charles Capouet Email & Phone Number

Washington D.C. Metro Area

• Drafted memoranda and spreadsheets regarding numerous state tax-related topics, including False Claims Act and class action risk, availability of net operating losses and credits following a merger, corporate income.
• Filed amicus curiae brief on behalf of the Broadband Tax Institute in New Cingular Wireless PCS LLC v. Commissioner of Revenue, No. 18-P-1317 (Mass. Ct. App. Sept. 4, 2020), regarding the Internet Tax Freedom Act’s.
• Drafted comments opposing proposed Alabama and Colorado regulations expanding rental and sales tax base to video services.

Washington D.C. Metro Area

• Drafted memoranda regarding numerous state tax-related topics including unclaimed property, cloud computing, digital goods, and state income, sales and use, excise, accommodations, and transfer taxes.
• Drafted protest of proposed assessment of sales tax on hotel accommodations and protest regarding a denial of the client’s use of the Multistate Tax Compact’s three-factor apportionment formula election.
• Drafted multiple protests filed with the DC Office of Administrative Hearings in response to proposed assessments issued by the DC Office of Tax and Revenue based on transfer pricing evaluations.
• Researched and drafted portions of a request for a declaratory opinion regarding whether a single event would create nexus.
• Researched Texas state and local tax incentives programs to assist in application for tax credits in exchange for the relocation of the client’s headquarters.
• Drafted and filed voluntary disclosure agreement requests in multiple states to remedy existing nexus risk.

• Prepared analyses of legislative bills regarding combined reporting, business and non-business income, financing, motor vehicle taxes, and net operating losses for a client, allowing the firm to determine its level of.

Washington D.C. Metro Area

• Externed with the State and Local Tax practice in the Washington, D.C. office.
• Created 50-state matrices detailing the legislative appeals and judicial process provisions, anti-limitations provisions on contracts with corresponding relevant case law, and life insurance provisions of unclaimed.
• Drafted preliminary entries for New York 'COST Developments: May – October 2012' article.
• Developed synopses on cloud computing and digital goods treatment across the 50 states to reflect recent developments in statutory, administrative, and case law.
• Drafted memo on New York case allowing use of intangible property in property factor numerator.

Washington D.C. Metro Area

• Researched tax issues for refund cases involving estate, partnership, and corporate taxation.
• Reviewed legal memoranda of the department prior to its use in meetings with taxpayers’ counsel.
• Drafted D.C. combined reporting regulations regarding partnership taxation.

Trenton, NJ

• Performed legal research for a deposition and a motion for summary judgment.
• Wrote motions for compelling a deposition, production of documents, a more definite statement and summary judgment in both federal and state courts.
• Reviewed documents for attorney-client privilege.

Hackensack, NJ

• Reviewed files and prepared drafts of preliminary orders for family law cases involving disputes over child custody, child support, and alimony payments.
• Wrote a memorandum discussing precedent applicable to cases heard before the judge regarding the child support obligations of an imprisoned father.

Master Of Laws (Ll.M.), Taxation

Activities and Societies: Honors: Dean's List, DistinctionObtained an LL.M. in Taxation with a Certificate in State and Local Taxation.

Doctor Of Law (J.D.), Law

Activities and Societies: The Tax Lawyer

Bachelor Of Science, Anatomy & Cell Biology