Jerald David "Jerry" August, Tax Attorney in Philadelphia, Pennsylvania

Mr. August is a nationally recognized tax lawyer who advises clients on income tax matters, including foreign taxation of U.S. businesses and U.S. taxation of foreign businesses and investors. In many instances he works with corporate and real estate counsel on selecting the proper entity in which to engage in domestic or foreign business or investment operations. He has been involved in structuring as well as negotiating merger and acquisitions, both taxable and non-taxable, joint ventures, financings, workouts and recapitalizations. He also represents clients in tax controversy and litigation in challenging the positions maintained by the Internal Revenue Service and other taxing authorities. He has also worked with the National Office of the Internal Revenue Service in filing private letter rulings or pursuing the competent authority provisions of a particular bilateral tax treaty involving the United States and a foreign country.

His work includes representation of public and private U.S. business entities, including private equity and hedge funds, as well as foreign public and private business entities, funds and individuals. Mr. August is frequently retained by law and accounting firms in advising their clients on tax and related matters as well as in working on tax disclosures required for SEC filings, IPOs and in evaluating issues related to contingent tax liabilities. He also represents high net worth individuals, including non-residents, on both U.S. and foreign income and wealth tax matters, including estate planning.

Mr. August is a frequent speaker and author on federal tax matters on topics ranging from international joint ventures and mergers and acquisitions to foreign tax credits, the use of defective entities in tax planning, and partnership formations, among others. August is a Life Sustaining Member of the prestigious American Law Institute (ALI) and regularly serves as program chair and speaker for ALI-CLE federal tax webcasts on various topics involving federal taxation. He also has for thirty years served on the Board of Advisors of the New York University Federal Institute of Taxation and is Chair of the Board of Advisor’s of the ALI’s long-standing tax law journal, The Practical Tax Lawyer. August has been a guest lecturer at the University of Pennsylvania Law School and the University of Pittsburgh School of Law, and a visiting professor on corporate income taxation at the Graduate Tax Program of the University of Florida School of Law. Mr. August is also a member of American College of Tax Counsel, the American College of Trust and Estate Counsel, and the American Tax Policy Institute. He is published annually on international taxation for Practicing Law Institute’s highly regarded (advanced level) Corporate Tax Practice Series called “Strategies for Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganization’s & Restructurings".

In addition to speaking at national federal tax law institutes and seminars, Jerry has authored well over one hundred articles published by national journals, including the Florida Law Review, on partnership, corporate and international taxation. He also is a noted legal authority on tax controversy matters, including the partnership audit rules and the attorney-client privilege and work product doctrine. Recently, Mr. August has spoken on various national and state bar association programs on recent business and international tax law changes, including the repatriation of accumulated foreign earnings and evaluating the potential benefits as well as problem areas resulting from the wide-sweeping domestic and international tax law enacted into law.

Mr. August has substantial experience in representing clients facing tax controversies before the Internal Revenue Service and other tax authorities, including trials before the United States Tax Court, the Court of Federal Claims, federal district courts, and the Eleventh Circuit Court of Appeals on a variety of tax matters. He also has been frequently involved in pre-indictment criminal tax investigations arising out of an audit or referral to the Criminal Investigation Division of the IRS. Mr. August has represented the Tax Section of the Florida Bar in writing and filing an amicus curiae brief with the Supreme Court in a landmark tax case, Commissioner v. Estate of Hubert, 520 U. S. 93 (1997).

Prior to joining Chamberlain Hrdlicka, Mr. August was a partner at Kostelanetz & Fink, New York, NY and spent 10 years as partner and co-chair of the Taxation and Wealth Planning Department of Fox Rothschild LLP and worked out of its Philadelphia and West Palm Beach Office. He also was the Chair of the Tax Opinions Committee. Prior to merging with Fox Rothschild LLP, Mr. August was the majority shareholder in the tax law firm of August, Kulunas, Dawson & Siegel, P.A., in West Palm Beach, Florida, which he started in 1988 after serving as Co-Chair of the Tax Department of the Miami-based firm of Steel Hector & Davis.