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Eric W. Olson
Eric W. Olson
Partner 
666 Fifth Avenue
20th Floor
New York, NY 10103
 
Tel:
212.822.2284
Fax:
212.880.8965
Cell:
917.270.0721
 
 

Represented businesses and individuals in tax controversies, including negotiation with and litigation before the Internal Revenue Service, New York State Department of Taxation and Finance, New Jersey Division of Taxation, New York City Department of Finance, and the New York City Tax Commission. Extensive experience negotiating, drafting governing documents, and closing sophisticated business transactions, including mergers, acquisitions, separations, joint ventures, workouts, and tax-free exchanges. Researched technical tax issues and drafted reasoned tax opinion letters. Evaluated, devised, and implemented estate-planning and asset protection strategies for high-net-worth individuals.

Representative clients include real estate developers, real estate management and holding companies, professional practices, manufacturers, distributorships, printing and direct mail businesses, broker/dealers, software development and database management businesses, and high-net-worth individuals.
 
Representative Experience
 
Tax Controversy
 
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Represented owners of New York City commercial real property seeking correction of real property tax assessments. Properties included high-rise office buildings, cooperative apartment buildings, residential rental buildings, warehouses, factories, multi-use properties, and other rental and owner-occupied properties.
 
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Defended business executives against imposition of personal liability for New York sales tax arising from assessment as responsible person.
 
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Represented pharmaceutical manufacturer in New York sales tax audit and established boundaries of production exemption in context of required quarantining of ingredients and products.
 
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Defended relocating corporation against application of New York City’s discretionary authority and resultant acceleration of income recognition.
 
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Represented New Jersey developer against IRS’ characterization of receipts as ordinary income, Olstein v. Commissioner of Internal Revenue, T.C.M. 1999-290 (Tax Ct. 1999)
 
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Advised manufacturer regarding imposition of throw out rule and resultant increase of New Jersey corporate business tax.
 
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Represented out-of-state taxpayers in residency tax audits and imposition of New York personal income taxes.
 
 
Tax Planning
 
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Advised parties to business acquisitions regarding New York transfer tax consequences, including real estate/property transfer taxes and sales tax.
 
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Drafted reasoned opinion letter advising art dealer on New York sales tax implications of purchase, repair, and delivery of multimillion dollar painting to out-of-state purchaser.
 
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Counseled institutional lender regarding modification of home equity lines of credit and supplemental mortgage exemption to New York mortgage recording tax.
 
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Formed and qualified New York and New Jersey private charitable foundations. Applied for and obtained IRS favorable determination letter designating Mircolumbia, Inc. as a not-for-profit public charity.
 
 
Corporate
 
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Redomesticated New York and New Jersey corporations to other states.
 
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Structured and implemented sale of New Jersey printing company to employee stock ownership plan.
 
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Negotiated and implemented intra-family separation of heating oil business.
 
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Structured and implemented real estate joint ventures.
 
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Represented seller of US-based fire extinguisher manufacturer with multinational operations.
 
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Tax-free corporate separation of real property and operational divisions of New York summer camp.
 
 
Healthcare
 
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Served as general counsel to large multi-discipline New York physician practice.
 
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Prepared and maintained physician practice's organizational documents.
 
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Negotiated and prepared physician employment agreements.
 
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Negotiated and prepared professional services agreements between physician practice and hospitals and other healthcare institutions.
 
Awards & Recognition
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ASCAP Nathan Burkan Memorial Copyright Award, Recipient, 1992
 
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Martindale-Hubbell, AV Rated
 
Published Works & Lectures
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144 New Jersey Law Journal 1267, "Legislature Widens Options for Professionals to Insulate Themselves From Liability," June 24, 1996
 
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141 New Jersey Law Journal 1904, "A Mechanism to Restrict Traditional Partner Liability," August 14, 1995
 
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18 Rutgers Computer & Tech. L.J. 879, Quoted, "Galoob v. Nintendo: Subject Matter Fixation and Consumer Fair Use Define the Scope of Copyright Protection For Interoperable Works," 1992
 
Professional Memberships & Activities
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Rutgers University School of Law, Adjutant Faculty Member, 2007 - present
 
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American Bar Association, Tax Section, Member
 
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New York Tax Study Group, Member
 
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Glen Ridge New Jersey Planning Board, Past Member, 2000-2005, Past Chairman, 2003-2005
 
Related Professional Experience
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Clerk to the Honorable Lawrence L. Lasser, New Jersey Tax Court, P.J.T.C., 1992-1993
 



Eric W. Olson

Practice
Tax
Education
LL.M. in Taxation, New York University School of Law, 1995
J.D., Rutgers University School of Law, 1992; Rutgers Computer & Technology Law Journal, Managing Production Editor
M.B.A., Bernard M. Baruch College, CUNY, 1987; Computer Systems
B.A., State University of New York at Albany, 1981; cum laude
Bar Admissions
New Jersey
New York
 
 
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