Conor McKenzie

Accomplished tax attorney with record of success in adeptly advising businesses on complex tax matters.

Conor brings extensive and deep experience in tax planning, controversy and advisory to his clients at DRM. An effective and trusted leader, he develops and implements tax strategies aligned with business goals to optimize the company’s overall tax position. He provides proactive advice on tax implications related to business initiatives, M&A, and other strategic decisions.

Having led the defense of US, state and local jurisdiction tax audits and controversies, Conor has the experience to work closely with tax authority auditors, hearing officers, the taxpayer (including various stakeholders) to resolve issues efficiently. He adds substantial value by guiding clients to mitigate tax risks through thorough analysis, tax planning, structuring and documentation of tax positions.

Conor excels in tax research and writing on a wide range of issues including federal income tax, state income franchise tax, sales and use tax, property tax, indirect tax in the context of tax opinions, tax technical memoranda, tax ruling requests, tax appeals and controversy.

When not working, Conor spends most of his time at various outdoors pursuits in Vermont with his wife and children. In the winter, he is generally at the mountain with his wife ringing cowbells, cheering on his kids at alpine ski competitions. When the snow is melted, Conor is often out cycling on Vermont’s network of dirt roads and singletrack trails.

Experience

• Obtained an abatement of assessed corporate income tax at the Massachusetts Department of Revenue Office of Appeals, successfully arguing for the correct apportionment of income for 40 Act mutual funds vs. non-40 Act mutual fund clients.

• Tracked and analyzed the development of the Massachusetts Market Based Sourcing apportionment regulation, advising clients on impact to their businesses and avenues to submit comments via industry groups.

• Assisted numerous business clients in reducing FIN 48 tax exposure for unpaid prior year taxes, interest and penalties through state tax voluntary disclosure agreements, limiting the number of years required to be filed and obtaining waivers of penalties.

Clerkships

Law Clerk to the Justices, Superior Court of Massachusetts, 2005-2006

Law Clerk – Massachusetts Appellate Tax Board (ATB), 2009

Community Involvement

Vermont Department of Taxes Commissioner’s Tax Administration Advisory Board – Member

Publications

• Massachusetts Supreme Judicial Court invalidates ‘millionaire’s tax’ ballot question as unconstitutional – EY Tax Alert I.D. No. 2018-0208

• S. Supreme Court Denies Cert of First Marblehead II, Massachusetts Supreme Judicial Court finding that Financial Institution Excise Tax meets Wynne internal consistency test upheld – EY Tax Alert I.D. No. 2017-0447

• New York Tax Appeals Tribunal holds application of Article 33 Tax on Insurance Corporations on alien insurance company violated nondiscrimination provisions of the US-German tax treaty – EY Tax Alert I.D. No. 2017-2097

• New York State Appellate Division find HMO not ‘doing an insurance business’ is subject to New York City’s General Corporation Tax – EY Tax Alert I.D. No. 2018-0208