Philip M. Tatarowicz
Professor, Graduate Tax Program
B.A., Illinois Benedictine College; J.D., Northern Illinois University; LL.M. (Taxation), Georgetown; CPA
Areas of Expertise:
B.A., Illinois Benedictine College; J.D., Northern Illinois University; LL.M. (Taxation), Georgetown; CPA. Professor Tatarowicz is a Professor in the Graduate Tax Program of the Law...Continue Reading
B.A., Illinois Benedictine College; J.D., Northern Illinois University; LL.M. (Taxation), Georgetown; CPA. Professor Tatarowicz is a Professor in the Graduate Tax Program of the Law Center, and is Of Counsel of the law firm of Morrison & Foerster LLP. He joined the Law Center as an adjunct in 1984, moving to full-time status in 2011. Professor Tatarowicz joined the full-time faculty and Morrison & Foerster following his retirement after 32 years in the National Office of Ernst & Young where he established and led that Big Four firm’s State and Local Tax (SALT) practice.
At Georgetown his current responsibilities include establishing and administering the State and Local Tax Certificate Program, coordinating its curriculum, and teaching courses that address multijurisdictional taxation, as well as Federal limitations on the powers of state and local governments to tax. Further, he serves as a faculty advisor to The Tax Lawyer and The State and Local Tax Lawyer; and, since 1982 has chaired the Law Center’s Advanced State and Local Tax Institute.
At Morrison & Foerster he continues his legal practice of providing controversy, as well as transactional and operational tax planning services to many of the world’s largest U.S.- and non-U.S.-based corporations doing business in virtually every major segment of commerce, including: industrial products; retail, consumer products, technology, communications, entertainment, energy, chemical, utilities, health sciences, financial services, real estate, hospitality, construction, aerospace, and insurance. His practice responsibilities include every type of state and local tax, with primary time spent on corporate income, property, payroll, sales and use, gross receipts, and other transaction based taxes.
In 2007, Professor Tatarowicz was appointed to the Internal Revenue Service Advisory Council (IRSAC), which offers recommendations on policies, programs and procedures, as well as tax administration issues. Over his four years of service on IRSAC, he held various positions, including the Advisory Council’s liaison to the IRS Office of Professional Responsibility. Further, he was and remains to date the first and only SALT professional ever appointed by the IRS to chair the full Advisory Council.
In 2012, for just the second time in its 36-year history, Professor Tatarowicz was awarded the Institute for Professionals in Taxation® prestigious Special Recognition Award. The award recognizes significant contributions by the recipient over an extended period to the advancement of the field of state and local taxation.
Professor Tatarowicz has been active in various industry and SALT reform commissions, professional advisory boards, and other professional organizations where he has assisted in the crafting of legislative and administrative tax proposals and testimony at the Federal, state and local levels of government. He has served as an expert witness in various court proceedings, and has served as a technical consultant to various law firms responsible for litigating controversies involving SALT issues before select Federal and state courts. In addition to being the former chairman of the American Bar Association's (ABA’s) Subcommittee on Interstate Transactions, he is:
• Past Chair of the ABA’s Committee on State and Local Taxation;
• Past Chair of the IRSAC, its Large Business and International Subgroup, and liaison to the IRS Office of Professional Responsibility;
• A member of the Association of Attorneys and CPAs, American Institute of CPAs, Illinois Bar Association, and Illinois Taxpayers Association;
• Serves on the State Tax Advisory Boards for several publishers, including Wolters Kluwer’s Legal Tax Advisory Board, Commerce Clearing House, Bureau of National Affairs, Panel Publications, Journal of Multistate Taxation, and Warren Gorham & Lamont; and.
• Former chairman of the Subcommittee on Sales, Excise, and Miscellaneous Taxes of the Chicago Bar Association, the State Tax Committee of the Greater Washington Society of CPAs, and the Tax Committee of the Chicagoland Chamber of Commerce.
Professor Tatarowicz has written numerous notes, commentaries and articles on a variety of multistate tax issues that have appeared in nationally distributed newspapers, magazines, professional journals, institute and symposia publications, and law reviews. He is frequently sought by members of the press for his views on current developments and emerging trends, and has been quoted in various publications and broadcasts. Also, he is a frequent chairman and speaker on state and local taxation to various professional groups both within and without the U.S.
• Philip M. Tatarowicz and Ted W. Friedman, Developments in Multistate Taxation, monthly column published for CCH’s Business Tax Journal.
• Craig B. Fields and Philip M. Tatarowicz, Complete Liquidations, State Tax Notes 189 (October 21, 2013).
• Craig B. Fields and Philip M. Tatarowicz, “Tax-Free” (IRC §351) Contribution to a Corporation, State Tax Notes 969 (June 17, 2013)
• Craig B. Fields and Philip M. Tatarowicz, State and Local Tax Implications of Reorganizing Business Enterprises: General Considerations and Select Taxes, State Tax Notes 427 (November 5, 2012).
• Philip M. Tatarowicz and William G. Nolan, Federal Courts and State Taxes: Select Jurisdictional Issues: Standing and Comity, 65 The Tax Lawyer 763 (Summer 2012)
• Craig B. Fields and Philip M. Tatarowicz, State and Local Tax Implications of Reorganizing Business Enterprises: The Marketplace and Its Challenges, State Tax Notes 329 (July 30, 2012).
• The Dormant Commerce Clause: Parceling State Actions Between Permissible and Impermissible Burdens, The State and Local Tax Lawyer (Spring, 2009)
• Federalism, The Commerce Clause and Discriminatory State Tax Incentives: A Defense of Unconditional Business Tax Incentives Limited to In-State Activities of the Taxpayer, 60 The Tax Lawyer 835 (Summer 2007)
• Factor Planning Opportunities, New York University Institute on State and Local Taxation (2000) (co-authored with Prentiss Willson).
• Right to a Refund for Unconstitutionally Discriminatory State Taxes and Other Controversial State Tax Issues Under the Commerce Clause, 41 The Tax Lawyer, 103 (1987)
• An Analytical Approach to State Tax Discrimination Under the Commerce Clause, 39 Vand. L. Rev. 879, 926 (1986) (co-authored with Rebecca F. Mims-Velarde)
• Problems in Allocating and Apportioning Income - an Overview and a Critique of Recent State Court Decisions, New York University Proceedings of the third Annual Institute on State and Local Taxation and Conference on Property Taxation (1985)
• Buying, Selling and Reorganizing Corporations, New York University Proceeding of the second Annual Institute on State and Local Taxation and Conference on Property Taxation (1984)
• State Judicial and Administrative Interpretations of U.S. Public Law 86-272, 38-2 The Tax Lawyer 293 (Winter, 1985)
Tax Technical Presentations - Seminars and Programs
• Georgetown University Law Center, National Institute on State and Local Taxation, Member of advisory board and chair
• New York University, State and Local Tax Institute, member of advisory board
• Council on State Taxation
• Hartman State and Local Tax Institute, founded in memory of Paul Hartman, Vanderbilt University Law School
• Tax Executives Institute: presentations include numerous addresses at its annual SALT school, national meetings, and each of its local chapters throughout the U.S.
• American Bar Association
• American Institute of CPAs
• Institute on Property Taxation
• Multistate Tax Commission
• National Council of State Legislators
• National Governors Association
• Federation of Tax Administrators
• California Tax Policy Institute
• Ohio Tax Institute
• Chicago Tax Club
• National Multistate Tax Institute
• DePaul University
• University of North Carolina at Chapel Hill
• Numerous other state bar associations, state CPA societies, and industry focused tax forums