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Terrence G. Perris

Senior Counsel

Terrence Perris focuses his practice on corporate income tax matters, emphasizing corporate restructuring, dispositions and acquisitions. Terry’s experience includes the taxation of international business transactions as well as general tax litigation, administrative practice before the IRS and other tax authorities (including obtaining advance letter rulings and prefiling agreements and mediating disputes with the IRS), and practice before the US Supreme Court. Terry is also experienced in the areas of individual federal income taxation and the taxation of S corporations, as well as the structuring of captive insurance company arrangements. He was named The Best Lawyers in America 2011 Cleveland Tax Lawyer of the Year. Terry is listed in Who’s Who in America, Ohio Super Lawyers, Who’s Who in American Law and has been listed in The Best Lawyers in America for more than 20 years.

Terry has extensive experience in counseling clients with respect to constitutional limitations on federal, state and local taxing powers. He counsels corporate clients regarding the use of tax-free corporate organization and reorganization techniques as acquisition and/or spin-off vehicles.

Prior to joining the firm, Terry served as a law clerk to Justice Potter Stewart of the United States Supreme Court; prior to that, he served as a law clerk to Judge J. Edward Lumbard, the former chief judge of the United States Court of Appeals for the Second Circuit.

Terry is a member of the American Bar Association’s Tax Section, Committee on Standards of Tax Practice. He is also a member of the Cleveland Metropolitan Bar Association’s General Taxation Committee. Terry has served as program chair, panel chair and general chair of the Cleveland Tax Institute. He is a member of Tax Practitioners of Cleveland, the Cleveland International Tax Forum and the Tax Club of Cleveland.

Terry has served as a visiting professor of law at the University of Michigan Law School, where he taught corporate taxation. He has also co-taught a seminar at the University of Michigan Law School on tax issues that arise in complex business transactions. He has also taught the course on corporate reorganizations in the LL.M. tax program at Case Western Reserve University Law School and has been a frequent lecturer on taxation issues at the Cleveland Tax Institute and other professional forums.

Terry is a co-author of a textbook, Taxation of S Corporations, with law professors from the University of Michigan and Washington and Lee University, published by Thomson/West in 2008. In addition he also co-authored, with the same two collaborators, “Corporate Income Taxation,“ published by Thomson/West in 2009. He also co-authored “All in the Family as a Single Shareholder of an S Corporation,” which appeared in Tax Notes in August 2007. In January of 2008, he published “Court Applies Work Product Privilege to Tax Accrual Workpapers,” which appeared in Practical Tax Strategies and which expanded on a shorter article that Terry had earlier written on the same subject for the on-line publication, Practical U.S./Domestic Strategies, in September 2007. With Squire Sanders partner Gordon S. Kaiser, Terry co-authored “The Sarbanes-Oxley Act and Auditor Independence,” published in The National Law Journal in 2003.

Reprezentatívne skúsenosti

    • Advising the governor and speaking to a joint session of the legislature, as special constitutional counsel to the state of Connecticut, on how to correct constitutional infirmities in the state’s corporate franchise tax and prevent the loss of more than US$1 billion in revenue.
    • Providing constitutional advice to petroleum companies in connection with a tax controversy involving Alaska’s proposed assessments of billions of dollars of tax liability; the controversy was resolved for a fraction of the state’s proposal.
    • Counseling a multinational public company in structuring a cross-border spin-off transaction separating business operations in more than 30 countries, secured a ruling from the IRS approving the spin-off structure and prepared a cross-border tax-sharing agreement to govern the post-spin-off tax relationships.
    • Advising a large public company in the structuring and implementation of a captive insurance company arrangement.

    Vzdelanie

    University of Michigan, J.D., Order of the Coif, summa cum laude, articles and book review editor, Michigan Law Review, 1972
    University of Toledo, B.A., magna cum laude, 1969

    Admissions

    Ohio, 1972
    U.S. Supreme Court
    U.S. Tax Court
    U.S. Ct. of Federal Claims
    U.S. Ct. of App., Federal Circuit