Sullivan & Worcester LLP advises on federal and state tax controversy matters, including administrative proceedings and litigation, alongside international planning and REIT taxation issues. The Boston-based practice is jointly led by Richard Jones, David Nagle, and Daniel Ryan. Jones handles disputes involving corporate nexus, domicile, apportionment, step transaction doctrine, and unitary reporting before state tax authorities, appellate tribunals, and the IRS. Nagle focuses on tax audits, administrative appeals, and state tax planning for complex business transactions. Ryan advises on federal and state tax litigation and related transactional planning involving corporate, franchise, sales and use taxes. Caroline Kupiec represents life sciences and technology clients in tax controversy matters.
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Key clients
- Lumen Technologies, Inc.
- Akamai Technologies, Inc.
- State Street Corporation
- Agero, Inc.
- Integrated IT Solutions
- Western Express, Inc.
Work highlights
Represented the taxpayer before the Massachusetts Supreme Judicial Court in Reagan v. Commissioner of Revenue, concerning the application of tax exemptions under G.L. c. 121A. The decision addressed incentives for private investment in blighted areas and has broader implications for state tax policy and affordable housing.
Represents Western Express, Inc., a large, nationwide transportation and logistics company in litigation against the Massachusetts Department of Revenue with significant constitutional ramifications.
Represented State Street Corporation in litigation before the Massachusetts Appellate Tax Board challenging a $17.9m assessment and the Department of Revenue’s position that financial institutions could not claim R&D credits. The Board ruled in favour of the taxpayer, and the Department declined to appeal.
Practice head
Richard Jones; David Nagle; Daniel Ryan
Other key lawyers
Caroline Kupiec