J Paul Varner

About J Paul Varner

J Paul Varner is a lawyer practicing tax, taxation of businesses, state and local tax and 7 other areas of law. J received a B.B.A. degree from University of Mississippi in 1977, and has been licensed for 44 years. J practices at Butler Snow LLP in Ridgeland, MS and 1 other location.

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Services

Areas of Law

  • Government
  • General Practice
  • Other 8
    • Tax
    • Taxation of Businesses
    • State and Local Tax
    • Tax Controversy
    • Tax Exempt Organizations
    • Wealth Transfer Planning (Domestic)
    • Estates and Trusts
    • Estate Administration/Probate

Practice Details

  • Firm Information
    Position
    Practice Group Leader, Tax Group
    Firm Name
    Butler Snow LLP
  • Representative Cases & Transactions
    Cases
    Experience: Controversies
    Fed Gift Tax Controversy. Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
    Fed Gift Tax Controversy. Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.
    Fed Estate Tax Controversy. Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.
    Fed Income Tax Controversy. Representation of taxpayers before the IRS Appeals Division
    the U. S. Tax Court to contest proposed assessments of income tax.
    State Tax Controversy. Representation of multi-state corporation in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.
    State Tax Controversy. Representation of out-of-state individual taxpayer in multi-million dollar Miss. income tax assessment
    taxpayer could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayer of approximately 25% of original assessment.
    State Tax Controversy. Representation of Fortune 500 company in multi-million dollar income tax assessment
    refund action in Miss. Chancery Court resulting in $4, 000, 000 refund (issue was whether gain on sale of business was business income or nonbusiness income under UDITPA).
    State Tax Controversy. Representation of Fortune 500 company in Million Dollar plus assessment of income tax from the disallowance of royalties paid to an affiliate for use of affiliate's intellectual property.
    State Tax Controversy. Representation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transaction. Weeks Dredging & Contracting, Inc. v. MS State Tax Commission, 521 So. 2d 884 (Miss. 1988).
    State Tax Controversy. Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.
    Planning
    Tax Deferred Exchanges. Representation of numerous taxpayers in structuring
    documenting forward
    reverse like kind exchanges of real property.
    Corporate Reorganizations. Representation of numerous corporations in structuring acquisitive
    divisive tax-free reorganizations.
    Private letter Rulings. Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS
    the Miss. State Tax commission.

Experience

  • Bar Admission & Memberships
    Admissions
    1982, Mississippi
    Memberships

    Associations

    American Bar Association

    Taxation Section

    State and Local Tax Committee

    Institute for Professionals in Taxation

    Capital Area Bar Association

    National Association of Property Tax Attorneys

    Mississippi Bar Association

    Taxation Section

    Mississippi Society of Certified Public Accountants

    Board of Governors, 1987-1989

    Board of Governors, 1997-1999

    Bar Fellowship
    American College of Tax Counsel

    The Best Lawyers in America®, Tax Law, Trusts and Estates

    Mid-South Super Lawyers®, Tax

    • Certified Public Accountant (Miss.)

    • Mississippi Legal Correspondent, State Tax Notes

    • Mississippi Tax Institute
    - Board of Trustees, 1993-1995

    • AV-rated, Martindale-Hubbell

    Associations

    • American Bar Association
    - Taxation Section
    -- State and Local Tax Committee

    • Institute for Professionals in Taxation

    • National Association of Property Tax Attorneys

    • Mississippi Bar Association
    - Taxation Section

    • Mississippi Society of Certified Public Accountants 1987-111997-11

    • Capital Area Bar Association

    Experience

    Fed Gift Tax Controversy. Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.

    Fed Income Tax Controversy. Representation of taxpayers before the IRS Appeals Division and the U. S. Tax Court to contest proposed assessments of income tax.

    Fed Estate Tax Controversy. Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.

    Fed Gift Tax Controversy. Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.

    State Tax Controversy. Representation of multi-state corporaton in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.

    State Tax Controversy. Representation of out-of-state individual taxpayers in multi-million dollar Miss. income tax assessment; taxpayers could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayers of approximately 25% of original assessment..

    State Tax Controversy. Representation of Fortune 500 company in multi-million dollar income tax assessment and refund action in Miss. Chancery Court resulting in $4,000,000 refund (issue was whether gain on sals of business was business income or nonbusiness income under UDITPA).

    State Tax Controversy. Representation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transactionn Weeks Dredging & Contracting, Inc. v. MS State Tax Commission, 521 So. 2d 884 (Miss. 1988).

    State Tax Controversy. Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.

    Tax Deferred Exchanges. Representation of numerous taxpayers in structuring and documenting forward and reverse like kind exchanges of real property.

    Corporate Reorganizations. Representation of numerous corporations in structuring acquisitive and divisive tax-free reorganizations.

    Private letter Rulings. Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS and the Miss. State Tax Commission.

    State Tax Controversy. Representation of Fortune 500 company in Million Dollar plus assessment of income tax from the disallowance of royalties paid to an affiliate for use of affiliate's intellectual property.

    Papers, Presentations & Publications

    • Co-Presenter, "Overview of Mississippi Sales and Use Tax," Lorman, 2011.

    • Presenter, "Tax Changes in the Healthcare Reform Act of 2010," Financial Planning Association of Mississippi, 2010.

    • "IRS Proposes New Audit Me Disclosure Requirement," Pointe Innovation, Spring 2010.

    • "Mississippi's Tax Commission is Replaced by Department of Revenue and Independent Board of Tax Appeals," Mississippi Tax Bulletin, July 2010.

    • "Change in Mississippi Contractor's Tax Impacts Refinery Owners and Contractors That Construct Improvements at Refineries," Mississippi Tax Bulletin, May 2010.

    • "New Mississippi Corporate Franchise Tax Regulation Many Tax Certain Loans from Affiliates," Mississippi Tax Bulletin, December 2009.

    • "The Tax Relief Act of 2010: An Overview of Business Incentives," Planning Notes, April 2011.

    • "The Tax Relief Act of 2010: An Overview of Estate, Gift and Generation-Skipping Transfer Tax Provisions," Planning Notes, January 2011.

    • "Planning for Largest Tax Increase in U.S. History," Planning Notes, November 2010.

    • "New Law Provides Significant Tax Breaks to Businesses," Planning Notes, September 2010.

    • "IRS Implements New Corporate "Audit Me" Disclosure Requirement," Planning Notes, August 2010.

    • "Estate Tax: Gone Today, But Still Requires Planning," Planning Notes, January 2010.

    • "Passive Activity Loss Rules: Members in LLC and LLP Are Not Limited Partners," Planning Notes, September 2009.

  • Education & Certifications
    Law School
    University of Mississippi
    J.D.
    1982 Editorial Board

    University of Mississippi
    J.D.
    Mississippi Law Journal

    New York University
    Class of 1984
    LL.M.
    Taxation
    Other Education
    University of Mississippi
    Class of 1977
    B.B.A.
    Accounting

J Paul Varner

Practice Group Leader, Tax Group at Butler Snow LLP
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Renaissance at Colony Park1020 Highland Colony Parkway, Suite 1400P.O. Box 6010Ridgeland, MS 39157U.S.A.

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Renaissance at Colony Park1020 Highland Colony Parkway, Suite 1400P.O. Box 6010Ridgeland, MS 39157U.S.A.

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