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Practice Areas Tax Planning for Mergers & Acquisitions Corporate Tax Law State Tax Planning State Tax Litigation Tax Audits and Appeals Tax Refund Claims Regulated Investment Companies Taxation of Advertising and Advertising Services Experience Bruce has worked with a broad spectrum of clients, ranging from large New York Stock Exchange companies to closely held corporations to individuals. Among the clients he has represented are International Business Machines Corporation, Target Corporation, Wells Fargo & Company, Amoco Corporation, U.S. Bancorp, Archer-Daniels-Midland Company, Cargill, Incorporated, E.I. du Pont de Nemours and Company, International Multifoods Corporation, Gannett Co., Inc., Kimberly-Clark Corporation, Piper Jaffray Companies, H.B. Fuller Company, UnitedHealth Group, Inc., Reliastar Financial Corporation, Aid Association for Lutherans/Lutheran Brotherhood, Graco, Inc., Guidant Corporation, Stellent, Inc., Principal Life Insurance Company, McData Corporation, Sharp Electronics Corporation, Fina Oil and Chemical Company, St. Paul Travelers Companies, the Guthrie Theater Foundation, and the Metropolitan Airports Commission. His practice focuses on the taxation of mergers and acquisitions and other corporate transactions in the federal area, as well as state and local taxation. During his career at Faegre & Benson, Bruce has been involved in the planning and implementation of numerous tax-free and taxable corporate transactions, including reorganizations, spin-offs, liquidations, redemptions, and the rules that treat stock purchases as deemed asset acquisitions. Bruce's work in the corporate area has involved not only regular corporations and S corporations, but specially taxed entities such as regulated investment companies. Bruce has extensive experience in the area of state taxation, and has represented clients in matters involving Minnesota tax law as well as the tax laws of other states. Work has involved income tax, sales and use tax, real and personal property tax, and health care tax, among others, and has entailed the planning of transactions for purposes of tax minimization and the representation of clients at the administrative level. Bruce has handled tax controversy work before the Departments of Revenue in Minnesota, Colorado, Iowa, Wisconsin, North Dakota, South Dakota, Illinois, Ohio, Missouri, Indiana, Kansas, New Jersey, Massachusetts, New York State, New York City, Pennsylvania, Alabama, Louisiana, Arkansas, West Virginia, New Mexico, Utah, and Arizona. Among the state tax issues with which Bruce has dealt are those involving nexus, unitary businesses and combined reporting, the apportionment of income, factor relief, add-back rules, throw-out rules, nonbusiness income, the utilization of foreign operating companies and intangible holding company structures, and the taxation of foreign source income. Other issues have involved the distinction between services and tangible personal property, the sales tax on advertising, the sales tax exemption for capital equipment, the sales taxation of construction contracts, the use of agency principles by exempt entities, enterprise zone benefits, domicile and residency, the taxation of former residents who receive deferred compensation, regulated investment companies, successor liability, and refund claims. In addition to planning transactions and representing taxpayers at the administrative level, Bruce is actively engaged in the Minnesota legislative and administrative rule making process. He has worked on the development of the Minnesota tax provisions relating to the corporate alternative minimum tax, the corporate taxation of foreign source income, the treatment of foreign operating companies, the taxation of foreign royalty income, the corporate dividend received deduction, and the sales and use tax provisions dealing with the exemption for capital equipment. Most recently, he was actively involved in the recodification of the entire Minnesota sales and use tax statute. In the rule-making area, he was integrally involved in the development of an entirely new and favorable rule relating to the sales and use taxation of advertising services, the modification of the proposed rule relating to the sales tax on capital equipment, and the amendment of the rules relating to the definition of a unitary business. Bruce is active in bar association matters. In addition to being a member of the Corporate Tax Committee of the Tax Section of the American Bar Association, he has been a member of the Executive Council of the Tax Section of the Minnesota State Bar Association. In that capacity, he has been Vice Chairman and Treasurer of the Tax Section, the Chairman of the Corporate Income Tax Committee, the Chairman of the Subcommittee on the Recodification of Chapter 270 of the Minnesota Statutes, a member of the Sales and Use Tax Committee, and a member of the Capital Equipment Subcommittee. He is the Tax Section's liaison to the MSBA for legislative affairs. Bruce was mentioned in the 2007 Legal 500, United States, under the category "Domestic Tax." Bruce received his law degree from Harvard Law School, a Masters in Business Administration degree from Columbia University Graduate School of Business, and his undergraduate degree from Cornell University. |
