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Jaye A. Calhoun

Jaye Calhoun is a partner in the New Orleans office of Kean Miller. She joined the firm in 2017 and practices in the tax group. Jaye provides clients with full-service tax representation covering federal, state, and local tax challenges and business opportunities. She has more than 25 years of experience and assists her clients with tax compliance and planning, guidance on the use of tax and business incentives, and represents clients in tax audits and controversies. She regularly represents clients in audits and administrative and judicial appeals before the IRS, the State of Louisiana Department of Revenue, and numerous local taxing authorities. Jaye is board certified by the Louisiana Board of Legal Specialization in both Taxation and in Estate Planning.

Jaye has been listed for a decade as one of the Best Lawyers in America (2007-2019), and in Louisiana Super Lawyers (2007-2018). She is AV-rated preeminent by Martindale-Hubble. She has been recognized by New Orleans City Business as a 2005 Woman of the Year and selected as a 2014 recipient of the Leadership in Law award. Jaye was also recognized by New Orleans Magazine as a Top Lawyer in 2012 and 2016 as a Top Woman Attorney by Louisiana Super Lawyers. She was elected as a Fellow of the American College of Tax Counsel (ACTC) in 2017.

Jaye is an Adjunct Professor of Law at Tulane University Law School, Loyola University New Orleans College of Law and Northeastern University D’Amore-McKim School of Business in Boston (online program). She is also a guest lecturer at Georgetown University Law Center in Washington D.C.

Representative Experience
  • Representation of clients, including multistate and global clients, with respect to federal, state and local taxation and regulatory issues, business planning and formation, Louisiana state entertainment tax credits, estate planning and planned giving, and federal, state and local tax collection matters
  • Representation of clients in obtaining guidance for tax and business compliance purposes and in the resolution of audits
  • Representation of a client in an effort that resulted in an HMO receiving a $500,000 state tax refund for income and franchise taxes
  • Secured a significant reduction of a $1.2 million proposed tax liability to a negligible amount for a hospitality business under state audit
  • Secured a $1 million abatement of federal tax penalties (following a delayed response) for a major financial services company, including counsel to help the client revise its procedures to improve risk management and avoid future penalties
  • Successfully argued a client’s tax case leading to a full concession by the state of a significant withholding tax issues
  • Successfully resolved a state tax dispute involving millions of dollars for a large publicly-traded gaming company
Education

Jaye earned her B.S. from Tulane University, H. Sophie Newcomb Memorial College in 1987. She earned her J.D. from Tulane University Law School in 1991, and her LL.M. from Georgetown University Law Center in 1997.

Admissions
  • Admitted, Louisiana and Texas
Leadership Positions
  • Public Service Fellowship Committee (2018 - 2021); Louisiana Tax Law Institute (Member, 2017-2019); Fellow, American College of Tax Counsel; American Bar Association Section of Taxation, State and Local Taxes Committee (Former Chair), Nominating Committee (2016-present), Subcommittee on Government Submissions and Legislative White Papers (former Chair), Publications Committee (2017); New Orleans Bar Association (Tax Law Committee Chair); Louisiana State Bar Association (Section of Taxation, 2004-2005 Chair, Estate Planning Advisory Commission); National Association of State Bar Tax Sections (Chair, Executive Board); 2015-2017 ABA/IPT Advanced Sales/Use Tax Seminar (Co-Chair); Georgetown Law’s SALT Institute Advisory Board (2016-present); Law360 Tax Editorial Advisory Board (2014)
Articles, Publications and Presentations
  • Panelists, ABA/IPT State Tax Work-Arounds, 2019 ABA/IPT Advanced State Income, Sales/Use & Property Tax Seminars, New Orleans, LA, March 12, 2019
  • Panelists, Recent SALT Developments, NYU's State and Local Conference, December 2018
  • Hot Tax Topics, Kean Miller Hospitality Forum, New Orleans, October 23, 2018
  • Co-Presenter, Damned If You Do, Damned If You Don't - Caught Between Qui Tam and Class Action, COST's 49th Annual Meeting, Phoenix, Arizona, October 2018
  • Louisiana - Dealing with Audits in the changing landscape, IPT Sales and Use Tax Symposium, Palm Springs, California, October 2018
  • Discussion Panelists, Implications of Wayfair Decision on State and Local Sales Tax Collection and an Update from Louisiana Sales and use Tax Commission for Remote Sellers, 2018 Annual Liaison Meeting with the Louisiana Department of Revenue and the Taxation Section of the Louisiana State Bar Association, September 28, 2018
  • Louisiana Department of Revenue Releases Post-Wayfair Guidance for Remote Sellers, Louisiana Law Blog, August 10, 2018
  • Louisiana Tax Changes Impacting the Hospitality Industry, Louisiana Law Blog, June 29, 2018
  • Louisiana Sales and Use Tax Rate Changes Cut the Additional Temporary Penny and Raise the Rate on Business Utilities - Effective July 1, 2018, Louisiana Law Blog, June 26, 2018
  • Louisiana Board of Tax Appeals Holds that the Individual Net Capital Gain Exclusion Applies to a Multi-Step Transaction, Louisiana Law Blog, June 21, 2018
  • Louisiana and Parishes Considering How to Realize Benefit from Scotus’ Wayfair Decision – Working to Change Effective Date of Enabling Legislation, Louisiana Law Blog, June 21, 2018
  • Panelists, Offshore Marine Service Association Tax Conference, March 28, 2018, New Orleans, LA
  • Speaker, Give Me One Good Reason to Set Up or Expand Business in Your State: A State Credit and Incentives Review, 2018 ABA/IPT Advanced Income Tax Seminar, March 19, 2018
  • Moderator, The Nexus Wars Escalate: State Taxes in The Age of Electronic Commerce, 2018 ABA/IPT Advanced Sales/Use Tax Seminar, March 21, 2018
  • Speaker, How to Recognize and When to Challenge Constitutional Issues in Ad Valorem Taxation, 2018 ABA/IPT Advanced Property Tax Seminar, March 22, 2018
  • Louisiana Department of Revenue Issuing Arm's Length Transfer Pricing Adjustments, Louisiana Law Blog, January 4, 2018
  • A Possible, Partial Solution to Unique SALT Issues Related to TEFRA Repeal, Journal of Multistate Taxation and Incentives (Thomson Reuters/Tax & Accounting), Volume 27, Number 9, January 2018
  • Contributor, ABA Section of Taxation, Multijurisdictional Admission to Practice Requirements for State and Local Tax Lawyers, November 2017
  • They Don’t Pay You Enough! How to Avoid Becoming Liable for Your Employer’s Taxes Under Responsible Person Statutes, IPT Insider, October 31, 2017
  • Gross Receipts Taxation - Why It's Hot (with States) and Why It's Not (With Taxpayers), COST's 48th Annual Meeting, Orlando, Florida, October 2017
  • State Tax Due Diligence in Merger and Acquisition Transactions: Sword or Shield?, ABA Tax Section Meeting, September 15, 2017
  • 2017 Louisiana Regular Legislative Session Ends on a Rather Anticlimactic Note, Louisiana Law Blog, June 23, 2017
  • It's Time to Amend Operating Agreements as the Result of TEFRA Repeal, New Orleans Bar Association Tax Law Committee, June 22, 2017
  • Local Taxes: How To Avoid Getting Caught Offguard by the Proliferation of New and Creative Local Levies, 2017 IPT Sales Tax Symposium, San Antonio, TX, September 2017
  • Sales and Use Tax Laws - Differentiating Between Exemptions and Exclusions Under Louisiana Law, ABA Tax Times, June 2, 2017
  • Corporate Income & Business Activity Taxes: Part 1, NYU Summer Institute in Taxation’s State and Local Tax Program, New York, NY, July 17, 2017
  • Mergers & Acquisitions Lap Two: Net Operating Losses, IPT Annual Conference, Charlotte, NC, July 11, 2017
  • Officer Liability: How to Keep Yourself (and your Boss) Out of Trouble, IPT Annual Conference, Charlotte, NC, July 11, 2017
  • Panelist, SALT Issues in Transactions Among Consolidated Group Members, ABA Tax Section Meeting, Washington, D.C., May 2017
  • Hot Topics in Sales and Use Tax for the Hospitality Industry, HFTP Greater Houston Chapter, Houston, TX, April 20, 2017
  • Louisiana Joins Other States Proposing Unpopular Gross Receipts Tax, New Orleans CityBusiness, April 13, 2017
  • Governor Edwards Proposes Comprehensive Louisiana Tax Reform Package, Louisiana Law Blog, March 30, 2017
  • Hot Topics in SALT: Louisiana State and Local Tax Update and More, 65th Annual Tulane Tax Institute, New Orleans, LA, November 2016
  • Nexus, Nexus, Nexus: - What Happens After Quill?, COSTS’s 47th Annual Meeting/Fall Audit Session, Las Vegas, NV, October 2016
  • N/A: Protecting Taxpayer’s Confidential Information, 39th Annual Advanced State and Local Tax Institute, Washington, DC, August 2016
  • Recent SALT Developments in the Southeastern States, with an Emphasis on Alabama and Louisiana, LCPA Summer Education Conference, Destin, FL, July 2016
  • Corporate Income and Business Activity Taxes: Part 1, NYU’s Summer Institute in Taxation’s State and Local Tax Program, New York, NY, July 2016
  • Jurisdiction and Nexus, Advanced Sales and Use Conference Interstate Tax Corporation, Miami Beach, FL, May 2016
  • LA Legislative Update: Important Tax Changes Impacting LA Nonprofits, New Orleans, LA, April 2016
  • What’s Next For Nexus After Latest Direct Marketing Opinion?, State Tax Notes: The Complete Practitioner, March 2016
  • 1st Special Session LA Legislative Update, New Orleans, LA, March, 2016
  • Keeping the Green in Your Pocket – An End-of-Season Webinar, March 2016
  • Tax-Exempt Entities: Paying the Way for Tax Exemption, 2016 ABA/IPT Advanced Income Tax Seminar, New Orleans, LA, March 2016
  • Federal and International Issues Affecting SALT, Both for Inbound and Outbound Taxpayers, 2016 ABA/IPT Advanced Income Tax Seminar, New Orleans, LA, March 2016
  • State IRC Conformity Issues, Tax Executive Institute(TEI), Houston, TX, February 2016
  • Author, BNA Navigator: Louisiana Corporation Income Tax, Spring 2015-present
  • Learning to Live with Economic Nexus, IPT Income Tax Symposium, Austin, TX, November 2015
  • Is Tax Reform Possible in Today’s Environment?, National Association of State Bar Tax Sections, Washington, DC, October 2015
  • SRSLY: I didn’t know that! (Sales and Use Taxes), 22nd Annual Paul J. Hartman State and Local Tax Forum, Nashville, TN, October 2015
  • Planning Through M&A and Tax Structure Changes, Council on State Taxation(COST) 46th Annual Meeting, Chicago, IL, October 2015
  • Collateral Tax Credit Issues Roundtable, National Association of State Bar Tax Sections, October 2015
  • Officer Liability, 2015 Sales Tax Symposium, Indian Wells, CA, September 2015
  • National Trends in State and Local Tax, Society of LA CPAs 2015 State and Local Tax Workshop, Baton Rouge, LA, July 2015
  • A High-Level Tax Discussion, State Tax Notes, June 2015
  • Lawyers React to High Court Limiting Md’s Taxing Power, Law 360, May 2015
  • High Court Levels Individual, Corporate Taxes in Md. Ruling, Law 360, May 2015
  • States Helping Themselves to Nationwide Tax Jurisdiction, Law 360, May 2014
  • Recent Developments – Taxation, Louisiana Bar Journal, Vol. 61. No. 1, June/July 2013
  • Recent Developments – Taxation, Louisiana Bar Journal, Vol. 60. No. 6, April/May 2013
  • Hooray for Hollywood! A Film-by-Film Primer on the Louisiana Film Industry’s Blockbuster Success Thanks to Motion Picture Tax Incentives, Louisiana Bar Journal, Vol. 58 No. 2, August/September 2010
  • Bender's State Taxation, Principles and Practice ("Local Taxes"), 2009-present
  • Taxation, Louisiana Bar Journal Vol. 57 No. 3, October/November 2009
  • Taxation, Louisiana Bar Journal Vol. 57 No. 2, August/September 2009
  • Recent Developments: Taxation, 56 Louisiana Bar Journal No.3, 2008
  • Working with Government Agencies in Tax Law: Leading Lawyers on Staying Up-to-Date on New Tax Laws, Understanding the Roles of Key Players in Tax Investigations, and Avoiding Trouble Spots for Corporate Clients (Inside the Minds), Aspatore, 2008
  • Louisiana Important Developments in State and Local Tax, The State and Local Tax Lawyer, Vol. 10, Page 215, American Bar Association, 2005
  • Recent Developments: Taxation, 52 Louisiana Bar Journal No. 4, 2004
  • Recent Developments: Taxation, 50 Louisiana Bar Journal No. 5, 2003
Community Service
  • Board Member and Secretary, Louisiana Chapter of the Association for Corporate Growth
  • Board Member and Steering Committee Member, Women in Film and Television Louisiana
  • Executive Board, Hospitality Financial and Technology Professionals Association
  • Former Board Member, American Red Cross, Southeast Louisiana Chapter
  • Member, New Orleans Estate Planning Council
  • Member, Women’s Professional Council
  • Sustainer, Junior League of New Orleans
Best Lawyers
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Super Lawyers
Jaye Calhoun Super Lawyers