Henry Stow Lovejoy

Henry Stow Lovejoy counsels clients on a full range of tax matters, from planning and structuring transactions to examination by and litigation with federal and state tax authorities.  He has extensive experience in many areas of the tax law, including the taxation of investments and financial products, the tax treatment of foreign individuals and dual residents, federal and state audits and appeals for individuals, partnerships and corporations, and penalty issues.  Mr. Lovejoy’s current practice focuses on US individuals investing and doing business abroad, foreign individuals investing in the United States, and taxpayers planning or under examination for complex financial transactions.  He also assists many clients in voluntary disclosures of offshore accounts, achieving the best results available under various federal and state programs.

Mr. Lovejoy graduated from Yale College and Columbia University School of Law.  Prior to joining Kostelanetz & Fink, LLP, he worked as a tax lawyer at several New York law firms and as a banker in capital markets, mergers and acquisitions, and structured finance. He is admitted to both the New York and New Jersey bars, and has been active in the Tax Sections of the New York State Bar Association, the New Jersey State Bar Association, and the American Bar Association.

Mr. Lovejoy has published articles on civil tax penalties and made presentations on a variety of subjects, including foreign tax credits, the economic substance doctrine, and the tax treatment of charitable donations.


Stow Lovejoy Representative Matters

  • Represented numerous clients making voluntary disclosures of offshore bank accounts.
     
  • Advised non-US family groups on structuring of investment in US real property.
     
  • Advised multinational family with respect to structure of worldwide business under US tax law.
     
  • Represented investment partnerships on IRS disallowance charitable deductions for donating historic façade easements with respect to landmark buildings.
     
  • Represented whistleblowers reporting over one billion dollars of unpaid income taxes to the IRS Whistleblower Office.
     
  • Represented individual investors in oil and gas drilling partnerships on IRS challenges to deductions.
     
  • Advised commodities exporter on export incentives under the Internal Revenue Code.
     
  • Represented investor in “distressed asset” tax shelter partnership at audit and in Tax Court.
     
  • Represented individuals and S corporation in contest of state tax allocation of “nowhere sales” to home state.

Presentations

“The Civil Fraudulent Failure to File Penalty: When It Applies and When It Does Not”, March, 2015. New York, NY.

“The STARS Transaction Decision and other Recent Applications of the Economic Substance Doctrine,” Committee of Banking Institutions on Taxation Spring Tax Day, June 25, 2013. New York, NY.

“The STARS Transaction Decision and other Recent Applications of the Economic Substance Doctrine,” ABA Tax Section, Banking and Savings Institutions Committee, May 10, 2013, Washington, DC.

“Recent Substance over Form and Debt vs Equity Cases,” ABA Tax Section, Banking and Savings Institutions Committee, January 25, 2013, Orlando, FL.

“Is there a Financial Transactions Tax in your Future?” ABA Tax Section, Banking and Savings Institutions Committee, September 14, 2012, Boston, MA.

“Foreign Tax Credits, Economic Substance and the Future,” ABA Tax Section, Banking and Savings Institutions Committee, February 17, 2012, San Diego, CA.

“Façade Easements: Historic Preservation or Tax Shelter?” ABA Tax Section, Individual & Family Taxation Committee, September 25, 2009, Chicago, IL.

Contact

Email: SLovejoy@kflaw.com

Tel: 212.808.8100


Publications

January 01, 2016

The ‘Good Faith and Cause’ Defense to Penalties


April 23, 2015

The Civil Fraudulent Failure to File Penalty: When It Applies and When It Does Not

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Education

Yale University, B.A. Enlish Literature (1974), cum laude

University of Wisconsin, M.A. English Literature (1976)

Columbia Law School, J.D. (1978), Harlan Fiske Stone Scholar


Bar Admissions

New York Bar, 1979

New Jersey Bar, 2004

U.S.D.C. Southern District of New York, 1979

U.S. Court of Claims

U.S. Tax Court, 2008