Representation of multiple NFL clubs regarding their respective billion-dollar stadium development projects. Structuring John Henry’s sale of the Florida Marlins and his simultaneous acquisition (as lead investor) of the Boston Red Sox, Fenway Park, and NESN as a tax-free like-kind exchange. Successfully resolved Fast Track appeal of a communications company’s tax treatment of a governmental fine, based on a novel legal theory and resulting in the deductibility of the majority of the fine. Negotiated an extremely favorable industry-wide settlement with the IRS National Office regarding the tax treatment of acquisitions of professional sports franchises and related assets. Secured “no change” letters in income tax audits of two sports leagues and three leagues’ for-profit affiliates (five separate audits). Lobbied the Treasury Department on a client’s fringe benefit issue, resulting in an example being inserted in new regulations adopting the client’s facts and proposed legal conclusion. Obtained reversal of an IRS Chief Counsel Advice memorandum regarding the tax treatment of a league-wide disability insurance program. Representation of an NFL club in a $275 million dispute with the IRS regarding stadium financing, player contracts, and broadcast agreements.Persuaded a state Department of Taxation to reverse its long-held, industry-wide position regarding sports clubs’ apportionment methodologies and to consequently drop 14 separate club audits.He also has significant experience counseling clients in the communications and media space on both transactional and controversy matters, and has advised clients such as, Sotheby’s, and Yahoo! regarding the federal and state taxation of e-commerce and similar multi-jurisdictional transactions. He has successfully represented clients at the IRS Examination and Appeals levels and in securing rulings from the IRS National Office on all the foregoing issues, as well as on the following topics: changes in accounting methods and periods, capitalization of tangible and intangible assets, deductibility of government fines, treatment of fringe benefits, and allowability of the Section 199 deduction. Jeremy's sports-related work encompasses such matters as the purchase and sale of sports franchises, public and private stadium financing, player compensation, the relationship between taxable and tax-exempt entities, franchise and network valuations, and the treatment of sponsorship, licensing, and broadcast agreements. ![]() Representative clients in the sports world include the National Football League, Major League Baseball, the National Basketball Association, the National Hockey League, Major League Soccer, the UFC, Fenway Sports Group, the United States Olympic Committee, and dozens of professional sports clubs. He is co-chair of the firm’s sports practice and a vice-chair of its tax group. Jeremy has been ranked as a leading tax lawyer in the Legal 500 US for his “superb legal advice and practical business guidance," by Chambers USA, which has noted his practice’s “dominant presence in the sports industry,” in Who’s Who Legal: Sports & Entertainment, as a Law360 MVP, and as a National Law Journal Sports Law Trailblazer. ![]() Jeremy Spector’s practice involves tax planning, IRS controversy work, and the structuring of corporate transactions, with particular emphasis on advising professional sports leagues and teams and on representing large taxpayers through the IRS audit, Fast Track, and Appeals processes.
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