Sullivan & Worcester LLP
David J. Nagle is a partner in the Tax Department of the Boston office of Sullivan & Worcester. His practice involves both transactional tax planning and representing taxpayers in disputes before the Internal Revenue Service and the Massachusetts Department of Revenue.
Representative client work includes: Complex business transactions, including taxable and nontaxable acquisitions, corporate and partnership restructurings and forward and reverse like kind exchanges Federal and state tax controversies, including income, sales and use, property and responsible person tax matters General federal and state tax matters.
Memberships: Bar & Court Admissions Massachusetts, 1997 U.S. District Court, District of Massachusetts U.S. District Court, District of Connecticut U.S. Tax Court U.S. Court of Appeals for the First Circuit.
Publications include: Snowbirds Beware: No Vacation from DOR, Boston Business Journal (May 2012); The Scope of Work Product In Massachusetts Tax Controversies, State Tax Notes (March 28, 2011); S&W Assists GLAD with Another DOMA Court Challenge, AmLaw Daily, New York Law Journal, Bay Windows (November 9, 2010); Court Rules Mass. Same-Sex Couples Can File Joint Tax Returns, WebCPA, Quoted (July 12, 2010); Pro Bono 2010: The Other Gay Marriage Case, The AmLaw Daily, Quoted (July 8, 2010); Mirror, Mirror: Identifying Property In a Reverse Like-Kind Exchange, Tax Notes (July 5, 2010); Lawyer’s E-mails to Co. Co-Owner Deemed Privileged, Massachusetts Lawyers Weekly, Quoted (May 10, 2010); Out-of-State Vendor Can’t be Taxed, Massachusetts Lawyers Weekly, Quoted (August 31, 2009); State Supreme Judicial Court Ruled in Favor of Client, Town Fair Tire, Inc., in Case Involving Collection of Use Taxes, S&W Press Release (August 25, 2009); Town Fair Tire Case, Various Publications, Quoted (August 2009); Case Could Extend State's Taxing Powers, Massachusetts Lawyers Weekly, Quoted (August 10, 2009); Destination Sourcing Might Resolve States' Conflict Over Sales Taxes, COST Official Says, Daily Tax Report, Quoted (July 16, 2009); New Hampshire Businesses Will Not Be Tax Agents for Massachusetts, Governor Vows, Weekly State Tax Report, Quoted (July 2009); Massachusetts Finalizes Combined Reporting Regulations, State Tax Notes (July 13, 2009); Welcome to TAXachusetts, Tire Business, Quoted (February 16, 2009); New Regs Set the Framework for Combined Reporting in Massachusetts, State Tax Notes (February 9, 2009); State Chases Sales Taxes in N.H., The Boston Globe, Quoted (February 3, 2009); Massachusetts Department of Revenue Releases Emergency Regulation Related to "Check-the-Box" Conformity, Practical U.S./Domestic Tax Strategies (December 1, 2008); Massachusetts Department of Revenue Restricts VDA Program for Banks and Intangible Holding Companies that Have Not Filed Returns, Practical U.S./Domestic Tax Strategies (June 2008); Massachusetts to Require Withholding by "Pass-Through Entities," Effective January 1, 2009, Practical U.S./Domestic Tax Strategies (May 1, 2008); and Billion-dollar battle over disputed taxes, Boston Business Journal, Quoted (April 28, 2008).
Teaching & Speaking Engagements: "Implementation of Unitary Combined Reporting in Massachusetts," Independent SALT Alliance (January 13, 2011); "Transfer Pricing: A U.S. International and Massachusetts Update," 1st Annual New England Federal Tax Forum, Massachusetts Continuing Legal Education, Inc. (MCLE) (December 3, 2010); Program Co-Chair, "Controversies & Litigation with the IRS & MA DOR," Massachusetts Continuing Legal Education, Inc. (MCLE) (November 3, 2010); Presented to the State Taxation Committee at the Massachusetts Society of Certified Public Accountants Meeting (July 22, 2009); "Privilege, Work Product & Kovel Arrangements," Independent SALT Alliance (ISA) (January 2009); "Changes in Massachusetts Practice Under the New Law," Suffolk University Law School and the Massachusetts Bar Association (September 19, 2008); Program Co-Chair, "Three Minute Case Studies," Boston Bar Association’s State & Local Tax Committee’s annual Massachusetts Tax Update (June 10, 2008); "Advanced Sales and Use Tax in Massachusetts," Lorman Education Services (July 2007); "Special Issues Affecting the Corporate Tax Basis in Massachusetts," Boston Bar Association (June 2007); and "Massachusetts Developments and Outlook for 2007," Tax Executives Institute (February 2007).
Awards & Honors: Legal 500 U.S. (2012) Best Lawyers’ 2012 Boston Litigation & Controversy - Tax Lawyer of the Year Best Lawyers in America (2011-2013); Chambers USA, Leading Lawyer in Tax (2010-2012); Massachusetts Super Lawyers (2010, 2011) "Rising Star," Massachusetts Super Lawyers (2005-2008) Professional & Civic Activities American and Massachusetts Bar Associations Boston Bar Association (Leadership Team, 2007-Present; Co-Chair, State & Local Tax Committee, 2006-2008; Tax Section Steering Committee, 2008-Present; Co-Chair, Tax Section, 2010) State Tax Committee of Associated Industries of Massachusetts (A.I.M.) Adjunct faculty member, Boston University School of Law, 2000 Former Writing Coach for Citizen Schools 8th Grade Academy Board of Directors, Independent SALT Alliance, 2010 President, Independent SALT Alliance, 2012
Education: B.A., with Honors, University of Virginia, 1991 M.A., University of Michigan, 1995 J.D., cum laude, Harvard Law School, 1997 LL.M., Taxation, Boston University School of Law, 2000