Michael J. Herzog is a Member in the firm’s Tax and Employee Benefits Departments. Mr. Herzog concentrates his practice on a variety of tax matters and employee benefits counseling. Mr. Herzog has assisted clients with the tax implications of business restructurings, mergers and acquisitions, due diligence reviews, technical research and drafting of tax memoranda, tax return compliance, tax return reviews and general tax advisory services. His experience also includes advising clients on many aspects of multi-state tax matters for large multi-state organizations, including income and franchise tax, sales and use tax and payroll tax matters.
Mr. Herzog has advised individuals, business owners and executives in various aspects of federal, state and local taxation including client representation before a variety of tax jurisdictions for audit defenses, settlement representation, tax credit litigation and administrative appeals and refund claims. He has also represented clients in summons enforcement, tax shelter matters as well as criminal tax investigations.
He has formed non-profit entities, advised non-profit board of directors as to various tax matters, assisted clients in fulfilling their tax-compliance filing obligations and resolved tax controversies for numerous non-profit entities.
Mr. Herzog’s employee benefits practice emphasizes tax-qualified retirement plans and executive compensation matters particularly the treatment of employee benefits in merger and acquisitions, the various uses of employee stock ownership plans (ESOPs), executive compensation issues such stock option and other equity-based compensation plans and the new tax rules regarding deferred compensation.
His experience includes preparing determination letter requests, reviewing annual returns/reports of employee benefit plans, filing voluntary compliance program submissions with the Internal Revenue Service, assisting clients with the termination of qualified retirement plans and advising plan sponsors as to the tax consequences of day-to-day plan operations.
J.D., University of Pittsburgh School of Law, 1999 (Cum Laude)
B.S., Pennsylvania State University, 1994
Pennsylvania, Virginia, U.S. Court of Appeals for the Fourth Circuit
