Michael James Guerriero

Obtained closing agreement on behalf of an international bank, limiting the bank's state income tax liability to water's edge

Obtained private letter ruling (PLR) from Georgia Department of Revenue to permit newly spun-off corporation to retain substantial ($50 million) investment tax credit eligibility

Advised with respect to PLR obtained from Pennsylvania Department of Revenue to exempt about $50 million in capital purchases from Pennsylvania Sales Tax; the PLR was obtained in advance of making the purchases and resulted in a sales tax savings of about $3 million

Advised major corporate client to acquire a $21 million software program electronically from a California vendor, which resulted in a savings of about $1.2 million in New Jersey sales tax

Advised with respect to a $4.5 million Pennsylvania use tax refund in connection with reverse (i.e., internal) use tax audit of a major manufacturing location

Advised with respect to casual sale exemption determination by Georgia Department of Revenue to exempt from sales tax the sale of an entire business operation, resulting in a sales tax savings of about $3 million

Negotiated $110 million reduction in full value of major corporate office and laboratory facility in Holmdel Township, NJ, resulting in an annual tax savings of about $1.75 million

Negotiated with Orange County, FL, tax assessor to obtain very favorable economic life for machinery and equipment used to manufacture microelectronic devices (e.g., computer chips), which resulted in annual personal property tax savings of about $1 million

Obtained determination from Ohio Department of Revenue to utilize most favorable economic life for machinery and equipment used to test wireless telecommunications products, resulting in a five-year tax savings of about $1 million

Advised with respect to five-year property tax exemption (about $500,000 in tax savings) for machinery and equipment used in the expansion of a major manufacturing facility in Oklahoma

Obtained favorable decision from Ohio Supreme Court exempting from sales tax an automatic storage and retrieval system used directly in manufacturing, resulting in a refund of about $350,000

Obtained favorable decision from Massachusetts Appellate Tax Board exempting from sales tax self-constructed machinery and equipment used directly in manufacturing; annual sales tax savings of about $1.5 million

Negotiated settlement of complex litigation involving the taxability of engineering services and computer software with the state of Washington attorney general resulting in $800,000 refund

Negotiated settlement with the Florida Department of Review of a Florida sales tax audit involving the purchase of material used to construct clean-room facilities at microelectronics manufacturing plant in Orange County, FL, resulting in sales tax savings of about $500,000

Obtained favorable decision from New Jersey Tax Court involving major manufacturing facility in Kearney, NJ, resulting in a reduction in the full value of about $15 million

Obtained favorable settlement of New Jersey Tax Court litigation involving a major corporate headquarters and laboratory facility in Murray Hill, NJ, resulting in a tax refund of about $5 million

Obtained favorable settlement of New Jersey Tax Court litigation involving major corporate facility in Whippany, NJ, resulting in tax refund/savings of $1.2 million

Obtained favorable decision from New York State Tax Appeals Tribunal in which the tribunal held that the New York Real Property Transfer Gains Tax did not apply to the acquisition of an interest in a limited partnership that leased a co-generation facility; the decision resulted in a tax refund of about $5 million