Eric A. French

T:  (678) 401-8147

F:  (678) 669-2395

E: eric.french@fisherbroyles.com

Atlanta Office

vCard

Eric A. French

Large Firm Experience:

  • Schiff Hardin LLP
  • Holland & Knight, LLP

Corporate Experience:

  • PricewaterhouseCoopers
  • Ernst & Young

Bar Admissions:

  • Florida
  • Georgia

Education:

  • Emory University School of Law, LL.M., Taxation, 1993
  • Michigan State University School of Law, J.D., 1992
  • University of Toledo, B.B.A., 1988

Mr. French concentrates his practice in state and local tax.  His expertise is primarily in the areas of corporate income and franchise tax, sales tax, property tax, payroll tax, and multi-state transactional tax.  He handles all types of business transactions, tax controversy, advocacy and litigation, legislative and regulatory activities, executive compensation and state tax planning.

State and Local Tax:

Mr. French has substantial experience in solving multi-state income and franchise and sales tax issues, including:

  • Providing strategic tax planning for corporate mergers, business transactions, restructuring of businesses, and acquisitions
  • Defending taxpayers in tax controversies and audit protests
  • Proactively identifying and securing state tax refunds and helping clients avoid tax pitfalls, as well as assist in the efficient structuring of transactions to avoid overpayment of tax obligations
  • Reducing tax liability in the millions of dollars for corporate entities, both for corporations as well as for high net worth individuals, including athletes and entertainers
  • Identifying and negotiating state tax credits, property tax abatements and other economic development incentives
  • Securing favorable state income and sales tax letter rulings
  • Negotiating state tax voluntary disclosure agreements
  • Providing companies with state tax ideas to increase profits and achieve their business objectives while reducing their overall effective state tax rates
  • Protecting the interests of clients with personal and business assets by advising them on the avoidance of transactions that create the appearance of impropriety

Tax Exempt Organizations:

In addition to state and local tax, Mr. French has significant experience working with tax-exempt organizations.  Examples include:

  • Advising tax-exempt organizations on tax-planning and their UBTI issues, IRS regulations imposing intermediate sanctions on “excess benefit transactions, and the general prohibitions against private inurement and private benefits to tax-exempt organizations
  • UBTI tax planning for tax-exemption organizations with for-profit operations
  • Formation of tax-exempt entities
  • Advising clients on making the most of their tax-exempt status, particularly public charity status
  • Exempt and non-exempt clients in audits before the Internal Revenue Service (IRS)

Representations:

Mr. French has significant experience in most jurisdictions in the southeastern U.S. in the area of income/franchise and sales/uses taxes as well as all 50 states in the continental U.S. and the District of Columbia.  His representations include:

  • Companies in all industries, including large manufacturers, retailers and many Fortune 500 companies that conduct business in multiple states
  • Middle market companies with their state and local tax planning and controversy matters
  • High-net-worth individuals, including professional sports figures and entertainers, with income tax planning, audit defense and voluntary disclosure agreements
  • Tax-exempt clients, including universities and colleges, foundations, religious organizations and other organizations with their federal and state unrelated business taxable income issues.

Publications:

  • “I Fought It On eBay: Internet Advertisers Versus the Tax Collector,” (contributor) In Fashion (Fall 2008)
  • “On-line and Mail-Order Retailers Are Subject To Michigan Business Taxes Even though They Have No Presence in Michigan,” (co-author) Tax Talk (May 2008)
  • “Warning for Illinois Taxpayers!  Illinois Form ICB-1 May Waive the Statue of Limitations on New Tax Assessments,” Tax Talk (July 2007)
  • “Stop the Running of Interest on Alleged Tax Deficiencies,”  Tax Talk (April 2007)