U.S. District Court for the District of Massachusetts
U.S. First Circuit
U.S. Tax Court
Mr. Gillig’s areas of focus include federal, state, and international tax planning, tax controversy and litigation, and other tax related services. He advises individuals, corporations, partnerships, non-profit organizations, and other entities on tax issues arising from day-to-day operations, as well as from a broad range of transactions, including entity formation and financing; acquisitions, mergers, and dispositions; international operations and assignments; joint ventures, and other matters.
Mr. Gillig has provided domestic and international tax services to clients in a variety of industries including publicly traded companies, private equity and hedge funds, family offices, business and commercial aviation, high-technology and other manufacturers, media and entertainment companies, software developers, internet companies, foreign exchange brokers and stock brokers, international commercial banks, S&Ls, hospitals and health care providers, colleges and universities, and charitable organizations.
Prior to joining Burns & Levinson, Mr. Gillig was a partner at another New England law firm. During his career he also worked for eight years at a major corporation, ultimately as Director of International Tax, as well as for more than ten years in Big Four public accounting. Mr. Gillig is also a certified public accountant.
Acquisitions, Dispositions, Joint Ventures, Reorganizations
- Separate sales of two medical diagnostic laboratories in S Corporation form for approximately $50 million each
- Tax due diligence and post-acquisition restructuring related to a $1.5 billion acquisition of a producer of industrial water treatment products and technology with operations in more than 20 countries
- Sale of a controlling interest in a manufacturer of high quality flooring for $26 million
- Structured Argentine joint venture between U.S. and Australian cinema owners
- Structured advice to a Philippine internet content provider
- Mutual savings bank to stock bank conversions
- Structuring acquisition of high value business aircraft by family offices, investment companies, commercial enterprises, and others, taking into consideration state sales and use taxes, federal transportation excise taxes, bonus depreciation, personal use, hobby loss rules, Federal Aviation Administration rules under Parts 91 and 135, as well as other matters
- Investment in and leasing of U.S. luxury residences by non-U.S. family office
- Formation of a South American eco-tourism resort and club owned by a U.S. LLC
- Acquisition of over 1 million acres of U.S. timberland by a privately held Canadian conglomerate
- Acquisition of a New York City office tower by non-US investors.
Export Incentives (IC-DISC)
- Numerous cross-border lending transactions into high-withholding-tax countries
- Design and implementation of tax efficient Canadian/U.S. "tower" intercompany financing structures
- Highly structured cross-border $750 million interbank financing
- Bankruptcy restructuring of the retail seller of quality plumbing fixtures, various workouts and restructurings involving real estate partnerships
- Formation and operation of IC-DISCs, including the preparation of tax returns applying marginal costing and transaction-by-transaction analysis to large numbers of transactions
- Tax efficient structuring of the ownership and operation of windmills in Germany
- Obtained innocent spouse relief with respect to an assessment based on unreported income in excess of $2 million
- Obtained favorable state tax settlement involving a sham allegation for a passive investment company
- Represented numerous taxpayers in voluntary disclosure of unreported foreign accounts
- Provided tax advice to individuals and companies regarding expatriate assignments and programs
Inbound Tax Planning
- Applied for and received exemption for structured charitable organizations operating in the U.S. and other countries
- Provide advice to exempt organizations regarding private incurement and other sensitive issues
- Provide advice regarding fractions rule and debt financed income/UBTI questions
- U.S. tax treaty planning for a variety of non-U.S. companies, including a retail boutique, a fishing and fish processing, a developer and manufacturer of rocket motors, a major producer of cultured pearls, a reinsurance company and a wood products company
- American Bar Association
- Boston Bar Association
- Massachusetts Bar Association
- American Institute of Certified Public Accountants
- International Fiscal Association
- Massachusetts Society of Certified Public Accountants
- National Business Aviation Association
- With tax directors from about 20 major U.S. multinational corporations, Mr. Gillig participated in a multi-day symposium to assist Harvard University in advising the United Nations on the adoption of a revised model tax treaty.
- Mr. Gillig also participated in the “Arkansas Best coalition” efforts to advise and influence the IRS regarding development of tax rules for hedging transactions.
- J.D., Syracuse University of Law,1982
- B.A., Syracuse University School of Management, 1980
Recent Articles and Publications:
What's Happening in Business Aviation?
Burns & Levinson Client Update, May 2013