Julian Fortuna, Corporate, Business, Tax Attorney

Julian A. Fortuna

Partner
jfortuna@taylorenglish.com
678.336.7191
  • Atlanta
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Clients should choose Taylor English to handle their domestic and international tax planning and tax controversy matters because the depth and breadth of our experience allow us to efficiently deliver a broad array of complex tax planning services and effectively represent our clients in any tax controversy.

Julian A. Fortuna focuses his practice on domestic and international tax planning and tax controversy matters. His industry experience spans clean energy, entertainment, health care, higher education, hospitality, manufacturing, non-profit, real estate and retail. Mr. Fortuna represents business entities, owners and executives, fiduciaries and beneficiaries of trusts and estates, and non-profit entities regarding all types of federal and state income, estate, and gift taxes. In tax controversies, Mr. Fortuna represents taxpayers in civil and criminal tax audits, investigations and administrative appeals before the Internal Revenue Service (IRS) and various state, local and foreign taxing authorities and in tax litigation before federal and state courts and tax tribunals. 

Prior to entering private practice, Mr. Fortuna was vice president and general tax counsel for InterContinental Hotels Group PLC (IHG), where he was responsible for structuring the international, federal, state and local tax impacts of mergers, acquisitions, dispositions and other corporate transactions, as well as construction projects, leases, exchanges, and other real and personal property transactions. He also directed tax research and planning for cross-border financing, captive insurance, and the worldwide use of trade names and other intangible assets. Mr. Fortuna represented IHG before the IRS and various other tax authorities on audits, appeals and ruling requests, and pursued tax regulatory and legislative changes for the benefit of IHG with U.S. Treasury and congressional personnel in Washington. Prior to joining IHG, Mr. Fortuna spent 11 years in the Tax Department at Deloitte and Touche, where he served a variety of corporate and individual clients, and prior to that he served four years in the U.S. Treasury Department at the Office of the Chief Counsel for the IRS, where he was responsible for litigation in the U.S. Tax Court.

Memberships

Atlanta Bar Association, Chair, Tax Law Section, 2014-2017

State Bar of Georgia, Chair, Taxation Law Section, 2016-2017

Georgia State University College of Law Low-Income Taxpayer Clinic, Advisory Board Member, 2016

Society of Trust and Estate Practitioners (STEP), 2017


Community Involvement

North Springs Charter High School Mock Trial Team, Volunteer Attorney-Coach, Atlanta Region 3 Champion, 2013

Practice Highlights

Experience

  • Tax planning for mergers, acquisitions and other corporate transactions

    Advised numerous corporate clients in structuring reorganizations, spin-offs, joint ventures, transfers to controlled corporations, and other tax-deferred transactions in connection with mergers, acquisitions and divestitures and other corporate transactions.

  • Tax planning for S Corporations, LLCs and partnerships

    Advised numerous S Corporations, LLCs and partnerships, and their owners, regarding initial qualification and the taxation of operating and investment income, raising debt and equity capital, executive compensation, and disposition of assets or entities.

  • ESOP transactions

    Represented business owners, plan sponsors, trustees, lenders, and related clients in a wide variety of tax issues arising in Employee Stock Ownership Plan ("ESOP") transactions ranging in value from $10-$300 million.

  • Tax planning for real estate transactions

    Represented group of investment entities on the tax-deferred sale of large tracts of real estate valued at more than $500 million. Structured all kinds of tax-free like-kind exchanges of real estate, including forward, reverse, construction and related-party exchanges.

  • Tax planning for renewable energy credits and grants

    Represented solar, wind, and biomass renewable energy developers in the structuring of entities to raise equity and debt supported by tax credits and grants.

  • International and domestic tax matters for large non-profit university

    Representing large non-profit university with respect to domestic and international tax planning, compliance and controversy matters.

  • International tax controversy

    Representing large, complex group of foreign entities, including a private foundation and its founders in an IRS examination involving classification and taxation of entities with more than $50 million of tax and penalties at stake.

  • Tax litigation

    Served as Plaintiffs' co-counsel in federal lawsuit against the IRS and individual defendants for unconstitutional viewpoint discrimination against non-profit educational and advocacy groups. Agreeing to a declaratory judgement, Attorney General Jeff Sessions acknowledged that the conduct of the IRS “was wrong and should have never occurred.”

  • Film tax credits

    Represented a bank lender in the financing of a tax credit syndicate using ownership interests in the entities owning film tax credits as collateral for the loan. 

  • Use of lodging facility by religious organization

    Represented one of the world's largest religious organization before the Georgia Department of Revenue, which agreed not to impose sales use and lodging taxes on use of lodging facility by church members and related groups.

  • Use of Lear Jet for business

    IRS agreed owner of Lear Jet entitled to interest, deprecation and operating expense deductions.

  • Tax planning for business transactions

    Representing business entities in a wide variety of industries on tax matters related to formation, financing, operations, restructuring, and dispositions.

Newsroom

Speaking Engagements

Headlines

Events

Education

Rutgers University School of Law, JD

Emory University School of Law, LLM

City University of New York, BA

Certified Public Accountant

Bar Admissions

Georgia

New York

Courts & Adjudicative Bodies

Georgia Tax Tribunal

U.S. Tax Court

U.S. District Court for the District of Columbia

U.S. District Court for the Northern District of Georgia

U.S. Court of Appeals for the District of Columbia Circuit

Accolades

Martindale-Hubbell® AV® Preeminent, Taxation, Resorts and Leisure, and Trusts and Estates, 2010-2016

The Best Lawyers in America®, Tax Law and Tax Controversy/Litigation, 2011-2019

Georgia Super Lawyers, Tax, 2012-2019

Georgia Trend's Legal Elite, Taxes/Trusts and Estates, 2011-2018

Georgia Tax Lawyer of the Year, Tax Law Experts, 2016-2017

"Five Star Award" for Estate Planning, 2014, 2015

Avvo, Inc. "Superb" 10/10 Rating, 2010-2015