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 manufacturing, hospitality, real estate, retail, health care, higher education and clean energy. 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.
Atlanta Bar Association, Chair, Tax Law Section, 2015-2016
State Bar of Georgia, Chair, Taxation Section, 2016
Georgia State University College of Law Low-Income Taxpayer Clinic, Advisory Board Member, 2016
North Springs Charter High School Mock Trial Team, Volunteer Attorney-Coach, Atlanta Region 3 Champion, 2013
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 in preparation for the establishment of ESOPs and other qualified employee benefit plans.
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.
Representing 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.
Representing 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.
Co-counsel in federal lawsuit seeking redress against the IRS and individual defendants for unconstitutional viewpoint discrimination against non-profit educational and advocacy groups.
Representing a large, international aircraft parts manufacturer in complex property tax dispute.
Representing one of the world's largest religious organizations in an unprecedented sales and use tax case.
Representing a bank lender in the financing of a tax credit syndicate using ownership interests in the entities owning the credits as collateral for the loan.
Represented business owners, plan sponsors, trustees, lenders, and related clients in a wide variety of tax issues arising in ESOP transactions ranging in value from $10-$300 million.
Georgia Department of Revenue agreed to limit sales tax 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.
Representing business entities in a wide variety of industries on top matters related to formation, financing, operations, restructuring, and dispositions.
Served as counsel to a Georgia manufacturer with operations across the U.S. in the establishment of an ESOP and sale of its stock to the related Employee Stock Ownership Trust, drafting and negotiation of all legal documents, working with investment banker and negotiating terms of sale with seller’s counsel, senior lender’s counsel and Trustee’s counsel. The matter involved a bank loan, stock purchase by the ESOP, a subsequent refinance and warrant ...
Represented Wilmington Trust Retirement and Institutional Services Company, Trustee of an Employee Stock Ownership Trust established by a large company in this transaction involving the sale of all of the common stock held by the ESOP to an outside party. Our ESOP team worked closely with ERISA and corporate counsel for the Company and with the ESOP Trustee and the Trustee's financial advisor to negotiate the terms and conditions of sale of the stock. The Trustee ...
Co-lead counsel to seller in negotiating sale of entire portfolio of residential development land holdings including with respect to tax advice for structuring transaction valued in excess of $200 million in 2014.
Represented Wilmington Trust Retirement and Institutional Services Company, Trustee of the Employee Stock Ownership Trust of a large company in a matter involving a large transaction under which the ESOP obtained 100 percent ownership of the Company. This was one of the largest ESOP transactions in the country in 2013, and it was one of two very large ESOP transactions closed by our firm in 2013. Our ESOP team negotiated the terms of the transaction and with ...
Represented Wilmington Trust Retirement and Institutional Services Company, Trustee of Martin Resource Management Corporation’s MRMC ESOP Trust (ESOP) in a complicated second stage ESOP transaction that resulted in approximately 100 percent ownership of the Company by the ESOP. We believe this transaction was one of the largest ESOP transactions in the country in 2013, and it was one of two very large ESOP transactions closed by our firm in 2013. Our ESOP ...
- "Creatives: Understanding the Business and Legal Side of Your Film Shoot in Georgia," 2016 Savannah Film FestivalOctober 22-29, 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
- "What is a §501(c)(3) Tax Exempt Organization and Its Limitations," 2016 Atlanta Bar Association March Madness Pro Bono EventMarch 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
- 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
- August 15, 2016
- February 19, 2016
- August 17, 2015
- February 20, 2015
- August 18, 2014
- December 5, 2013
- Employee Benefits and Executive Compensation
- Employee Stock Ownership Plans (ESOP)
- 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
- Leisure and Hospitality
- Public Interest and Advocacy
Rutgers University School of Law, JD, 1980
Emory University School of Law, LLM, 1984
City University of New York, BA, 1977
Certified Public Accountant, 1987
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
Georgia Trend Legal Elite, Taxes/Trusts and Estates, 2011-2014
Tax Law Experts, Lawyer of the Year, 2016-2017
"Five Star Award" for Estate Planning, 2014, 2015