Profile
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, Taxation Law Section, 2014-2017; Vice-Chair International Law Section, 2018-Present
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
Representing business entities in a wide variety of industries on tax matters related to formation, financing, operations, restructuring, and dispositions.
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.
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.
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.
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.
Represented solar, wind, and biomass renewable energy developers in the structuring of entities to raise equity and debt supported by tax credits and grants.
Representing large non-profit university with respect to domestic and international tax planning, compliance and controversy matters.
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.
Successfully litigated claims that the IRS imposed unconstitutional viewpoint discrimination against 41 non-profit educational and advocacy groups.
Represented film production companies in the planning, application and defense of film tax credits.
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.
IRS agreed owner of Lear Jet entitled to interest, deprecation and operating expense deductions.
Assisted a fund manager in evaluating, structuring, and executing on three transactions that qualified for the Opportunity Zone Program.
Newsroom
Speaking Engagements
- December 15, 2020
- April 28, 2020
- March 2, 2020
- December 5, 2019
- Nov. 13-17 2019
- October 1, 2019
- May 29, 2019
- Clear Law InstituteMay 8, 2019
- Real Estate and Property Tax TrendsApril 25, 2019
- March 11, 2019
- January 16, 2019
- December 13, 2018
- November 29 – 30, 2018
- Choice of Entity Tax Considerations for Breweries and Distilleries, National Business InstituteAugust 10, 2018
- Recipes for Success | Tip Pooling: What Employers Need To Know, An Interactive Hospitality and Retail Law SeriesJuly 24, 2018
- Lights, Camera, Action: The Georgia Film Tax Credit and Legal Issues Regarding the Local Film Industry, Atlanta Bar AssociationFebruary 27, 2018
- "Tax Issues in Estate Administration," National Business InstituteOctober 11, 2017
- May 26-28, 2017
- March 23, 2017
- December 15, 2016
- December 9, 2016
- October 22-29, 2016
- October 13, 2016
- "ESOPs," 15th Annual North Carolina/South Carolina/Georgia Tax Section WorkshopsMay 29, 2016
- "Taxation of Settlement Payments," 15th Annual North Carolina/South Carolina/Georgia Tax Section WorkshopsMay 28, 2016
- March 22, 2016
- "Recent Developments in the Taxation of Settlement Payments in Employment and Commercial Litigation," 2016 State Bar of Georgia Midyear MeetingJanuary 7, 2016
- Panel Moderator, "1031 Hot Buttons: Current Tax Issues in Like-Kind Exchanges," State Bar of Georgia Institute of Continuing Legal EducationDecember 17, 2015
- Panelist, "IRS and DOJ Voluntary Disclosure and Whistleblower Programs," Atlanta Bar Association, Criminal Law SectionNovember 11, 2015
- Panel Moderator, "The Nuts and Bolts of ESOPs," Atlanta Bar Association, Tax Law SectionOctober 19, 2015
- June 19, 2015
- "Recent Federal Income, Estate and Gift Tax Developments," Georgia Society of CPAsApril 21, 2015
- The Best of CLE Seminar, Tax LawFebruary 25, 2015
- "2014 Income, Estate and Gift Tax Developments," The Seminar GroupFebruary 25, 2015
- "A Primer on 'Tax Free' Corporate Reorganizations and the Transfer of Tax Attributes," State Bar of Georgia Institute of Continuing Legal EducationDecember 18, 2014
- "TEFRA Partnership Litigation," State Bar of Georgia ICLEApril 24, 2014
- "2013 Income, Estate and Gift Tax Update," The Seminar GroupFebruary 27, 2014
- "Recent Federal Income, Estate, and Gift Tax Developments," Tax TalksFebruary 26, 2014
- "Hot Topics in Exempt Organizations," State Bar of Georgia ICLE2013
- "Tax Aspects of Divorce," The American Society of Attorney-CPAs2013
- "Recent Developments in Income, Estate and Gift Tax Planning," The Seminar Group2012
- "Recent Developments in Income, Estate and Gift Tax Planning," The Seminar Group2011
- "Recent Developments in Income, Estate and Gift Tax Planning," Gwinnett Bar Association2010
- "Addressing Liquidity Concerns Upon the Death of An Owner of a Closely-Held Business," 2009
- "Recent Developments in Income, Estate and Gift Tax Planning," Atlanta Bar Association2009
Publications
- September 15, 2020
- October 18, 2019Georgia Bar Journal
- June 2018ACC Docket
- March 6, 2018
- July 31, 2017
- "Transfer Pricing Adjustment Challenges Receive Green Light from the Tax Court,” Journal of TaxationNovember 11, 2016
- September 30, 2016
Headlines
- March 4, 2020
- December 6, 2018
- November 28, 2018
- August 9, 2018
- June 4, 2018
- September 22, 2017
- September 13, 2017
- April 3, 2017
- April 3, 2017
- December 16, 2016
- December 16, 2016
- December 16, 2016
- December 16, 2016
- October 19, 2016
- October 19, 2016
- September 23, 2016
- August 17, 2016
- August 17, 2016
- August 10, 2016
- August 8, 2016
- April 18, 2016
- April 15, 2016
- January 6, 2016
- April 10, 2015
- January 14, 2014
- June 3, 2013
News Releases
- December 3, 2020
- August 20, 2020
- February 24, 2020
- August 15, 2019
- February 20, 2019
- December 6, 2018
- August 15, 2018
- Nine Attorneys Also Recognized as Leaders in Their FieldsMay 3, 2018
- February 22, 2018
- December 4, 2017
- February 23, 2017
- December 15, 2016
- December 13, 2016
- August 15, 2016
- February 19, 2016
- August 17, 2015
- February 20, 2015
- August 18, 2014
- December 5, 2013
Alerts
- July 22, 2020
- Information Current as of June 3, 2020
- Information Current as of May 4, 2020
- March 19, 2020
- By: Julian FortunaJune 26, 2019
- By: Julian FortunaApril 30, 2018
- By Julian FortunaMarch 2, 2018
- February 6, 2018
- January 23, 2018
- November 27, 2017
- October 6, 2017
- August 22, 2017
- March 7, 2017
- October 13, 2016
- September 26, 2016
- September 22, 2016
- May 24, 2016
- June 3, 2014
- May 31, 2014
Events
- October 9, 2018
- An Interactive Hospitality and Retail Law SeriesJuly 24, 2018
- September 25, 2013
Services
- Tax
- Employee Benefits and Executive Compensation
- Employee Stock Ownership Plans (ESOP)
- Opportunity Zone Transactions
- Succession Planning for Closely-Held Businesses
- Tax Controversy and Litigation
- Tax Credits and Special Incentives
- Tax Planning for Business Transactions
- Tax-Exempt Organizations and Charitable Giving
- Trust, Estate, and Family Wealth Planning
- Corporate and Business
- Employee Benefits and Executive Compensation
- Entertainment, Sports and Media
- Financial Institutions
- Higher Education and Research Parks
- Leisure and Hospitality
- Manufacturing
- Non-Profit
- Public Interest and Advocacy
- Retail
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 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, 2010-2019
The Best Lawyers in America®, Tax Law and Tax Controversy/Litigation, 2011-2021
Georgia Super Lawyers, Tax, 2012-2020
Georgia Trend's Legal Elite, Taxes/Trusts and Estates, 2011-2018, 2020
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, 2010-2019