As the long-time leader of the firm’s State and Local Tax Law Practice Group, Michael Sontag has represented a multitude of Fortune 500 companies in their effort to ensure fair tax treatment by state and local governments, thereby avoiding the imposition of hundreds of millions of dollars of improper taxes. He has developed a national reputation and is the go-to solution for out-of-state and in-state companies alike confronting Tennessee state and local tax controversies. Michael and his team have assisted taxpayers in audits, administrative reviews and, when necessary, litigation. Michael has also developed innovative strategies for reducing a company’s exposure to state and local taxes, whether through restructuring transactions or through legislative solutions designed to provide tax-advantaged treatment where appropriate.
Michael was the first attorney to successfully challenge on Commerce Clause grounds the income taxation of out-of-state banks having no physical presence in Tennessee as well as the imposition of business taxes to certain wholesale sales of pharmaceuticals for the world’s largest pharmaceutical company.
Michael has built his national reputation through his steadfast dedication to his craft, both through his representation of clients as well as numerous speaking engagements and scholarly articles presented to national audiences.
Nashville Bar Association — Board Member
Tennessee Bar Association
American Bar Association
Represented Tennessee Steel Haulers, Inc. in its sale to Daseke, Inc.
Represented LoJac Holdings Corp. in its sale of three divisions to Vulcan Materials Co.
Represented Pfizer and its affiliates in litigation claiming more than $120 million in franchise and excise tax refunds
Represented Aabakus in a tax refund claim
Successfully represented Equifax in a case of first impression concerning the breadth of the telecommunication tax
Represented General Mills, Inc. in successful litigation seeking a refund of use taxes
Represented ConAgra Foods, Inc. in litigation regarding the Commerce Clause and Due Process Clause
Represented Edwin B. Raskin Company in the successful defense of a tax refund claim
Represented Qualcomm Incorporated in litigation where the court held Qualcomm’s services were not taxable
Advocated for a decision that IBM’s wide area network service was not a telecommunications service subject to sales tax
Chambers High Net Worth Guide — Private Wealth Law (2017-2018)
Best Lawyers in America® — Nashville Litigation and Controversy: Tax “Lawyer of the Year” (2019, 2012)
Best Lawyers in America® — Administrative/Regulatory Law; Litigation: Trusts and Estates; Litigation and Controversy: Tax; Trusts and Estates (1995-2019)
Nashville Business Journal “Best of the Bar” (2013)
Mid-South Super Lawyers (2006-2017)
Top 100 Tennessee Super Lawyers (2012-2013)
Top 50 Nashville Super Lawyers (2012-2013)
Business Tennessee “Top 150 Lawyers in Tennessee”
Nashville Post “Nashville’s 101 Top Lawyers” (2011)
Nashville Post “In Charge” (2012)
Vanderbilt University Law School/Paul J. Hartman State and Local Tax Forum — Trustee and Former President
Tennessee Federal Tax Institute — Trustee and Former President
“Tennessee Taxes” CCH Guidebook — Contributing Editor