Current Employment Position(s)

Partner

Lawyer Overview

John Allan has practiced exclusively in the multistate tax area for more than 17 years, working extensively in all areas of multistate tax planning and tax controversies.

John is a member of the State Bar of Georgia, an appointed member on the Committee on State and Local Taxation of the American Bar Association, and previously served as editor-in-chief of the American Bar Association's State and Local Tax Lawyer. He currently chairs the Georgia Department of Revenue's Advisory Committee and is a former chair of the Southeastern Association of Tax Administrators (SEATA) Advisory Council.

John speaks frequently on state and local tax matters before such groups as the Council on State Taxation (COST), the Tax Executives Institute (TEI), the Federation of Tax Administrators (FTA), and SEATA. Recent articles coauthored by John and published in The State and Local Tax Lawyer include: "The Extraterritorial Assertion of State Taxing Power: Onward to the Past," Vol. 2, 1997; "Defending Against a Geoffrey Assessment: Statutory Problems Inherent in Economic and Intangible Based Nexus Theories," Vol. 3, 1998; and "Commerce Clause Implications of Locally Imposed Gross Receipts Based Taxes," Vol. 8, 2003.

Areas of Practice

• Tax
• Mergers & Acquisitions/Tax
• Private Equity/Tax
• State and Local Tax Controversies
• State and Local Tax Counseling
• Tax Audits & Controversies

Representative Cases

• Acquisition of Susquehanna Radio , (2005)

West Practice Categories

Banking & Finance Law, Corporate Taxation, Estate & Gift Taxation, Excise Taxes, Income Taxation, International Taxation, Mergers, Acquisitions & Divestitures, Payroll Taxes, Property (Ad Valorem) Taxes, Sales & Use Taxes, State, Local & Municipal Law, Taxation Law

Bar Admissions

• Georgia

Education

• U of Georgia

Published Works

• Texas Comptroller Transfers Administrative Tax, 2007
• Tax Shelters, Business Purpose And You (Ethics), TEI Dallas Chapter, Jones Day State Tax Return, 2005
• Current Federal And State Audit Experience: Will Our Therapy Bills Be Deductible?, TEI Dallas Chapter, Jones Day State Tax Return, 2005
• Multistate State Tax Update, TEI Dallas Chapter, Jones Day State Tax Return, 2005
• The SSTP Has Landed: Dealing With The Streamlined Sales Tax Rules, TEI Dallas Chapter, Jones Day State Tax Return, 2005
• Is Your Company's Auditor Independent? Proposed New Rules Address Tax Services PCAOB Release No. 2004-015 (July 26, 2005), Jones Day State Tax Return, 2005
• Select State Tax Implications Of Conformity To Qualified Production Activity Income Deduction, Jones Day State Tax Return, 2005
• California Franchise Tax Board Defines Personal Services For Purposes of Apportionment, Jones Day State Tax Return, 2005
• "Cost Of Performance" Means All Such Costs, Jones Day State Tax Return, 2005
• California Appellate Court Holds That The Franchise Tax Board May Exclude Returned Principal From Taxpayers’ Gross Receipts, Jones Day State Tax Return, 2005
• Can Being Passive Be A Good Thing? Missouri Supreme Court Rules That Interest On Funds Invested By Out Of State Parent Is Nonapportionable Income, Jonese Day State Tax Return, 2005
• Alabama Circuit Court Rules that the State May Tax the Alabama-Source Income of Nonresident Limited Partners in Alabama Partnerships, Jones Day State Tax Return, 2005
• Trademark Holding Companies are Subject to North Carolina Franchise and Income Taxes, Jones Day State Tax Return, 2005
• Tennessee Supreme Court Holds Catalysts Fall Within the Scope of the Industrial Machinery Exemption, Jones Day State Tax Return, 2005
• One Statute, Two Interpretations of Legislative Intent: The Georgia Courts Address the Research Tax Credit, Jones Day State Tax Return, 2004
• Corporations That Licensed Intellectual Property to Restaurants Deemed Subject to North Carolina Income and Franchise Tax, Jones Day State Tax Return, 2004
• Multi-state State Tax Update 2004, TEI Dallas Chapter, 2004
• Tax Reserves, Tax Planning and Workpapers: 'Are My Tax Documents Privileged?' TEI Dallas Chapter, 2004
• Taxpayer Fails to Catalyze the Tennessee Court of Appeals to Expand the Industrial Machinery Exemption, Jones Day State Tax Return, 2004
• Business Purpose Doctrine, TEI Dallas Chapter, 2004
• Federal and State Tax Shelter Developments, TEI Dallas Chapter, 2004
• Sarbanes-Oxley Implications for the SALT Professional, COST, Baltimore, MD, 2004
• Run, Here Come the Cops - Troublesome New California Anti-Tax Shelter Provisions; Recent MTC Tax Shelter Report and Activities, Jones Day State Tax Return, 2004
• State Tax Update 2004 on Intangible Holding Companies, TEI Dallas Chapter, 2004
• Corporate Governance 2004 - Independence and Your Tax Department: Disclosure, Reserves, Working With Your Auditor and Your Audit Committee, etc., TEI Dallas Chapter, 2004
• Business Purpose and State Tax Shelter Legislation, TEI Dallas Chapter's Current Developments Tax Seminar, 2004
• Intangible Holding Companies: M&A Apportionment, Nexus and Texas Implications, TEI Dallas Chapter, 2004
• In Texas, Form Over Substance Rules: Comptroller Makes an End Run Around Statutory Prohibition of Push Down Accounting, Jones Day State Tax Return, 2003
• Business Purpose: It Has to Make Sense, SEATA, Savannah, GA, 2003
• Maryland Highest Court Rules on Intangibles Holding Companies, Jones Day State Tax Return, 2003
• The Empire Strikes Back - New York Tax Appeals Tribunal Overturns Favorable Decision in Sherwin-Williams, Holds Sherwin-Williams Responsible for Filing Combined Returns With Its Intellectual Property Holding Companies, Jones Day State Tax Return, 2003
• Different California Courts - Same Result, Jones Day State Tax Return, 2003
• State Tax Issues of Intercorporate Intellectual Property Transfers, TEI Ashville Chapter, 2003
• Sarbanes Oxley Revealed! (And What it Means to Your Tax Department), Chicago Tax Club, 2003
• The Final Auditor Independence Regulations: New Considerations for Corporate Tax Departments, Jones Day State Tax Return, 2003
• The Final Auditor Independence Regulations: New Considerations for Corporate Tax Departments, Jones Day State Tax Return, 2003
• Limited Partners Beware - The Alabama Department of Revenue Seeks to Hold Nonresidential Limited Partners Liable for Alabama Personal Income Taxes on Gains and Income Derived by an Alabama Limited Partnership, Jones Day State Tax Return, 2003
• Georgia Issues Consolidated Return Regulations, Jones Day State Tax Return, 2003
• Impact of the SEC Final Rules under the Sarbanes-Oxley Act of 2002 on Non-Audit and Tax Services Provided by Auditors, 2003
• Commerce Clause Implications of Locally Imposed Gross Receipts Based Taxes, The State and Local Tax Lawyer, Vol. 8, 2002
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 10, 2002
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 8, 2002
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 3, No. 6, 2002
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 9, 2001
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 4, 2001
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 3, 2000
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 2, No. 1, 2000
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 12, 2000
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 9, 2000
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 7, 2000
• Recent Developments -- Multistate Taxation, Corporate Business Taxation Monthly, Vol. 1, No. 4, 2000
• Defending Against a Geoffrey Assessment: Statutory Problems Inherent in Economic and Intangible Based Nexus Theories, The State and Local Tax Lawyer, Vol. 3, 1997
• The Extraterritorial Assertion of State Taxing Power: Onward to the Past, The State and Local Tax Lawyer, Vol. 2, 1996

Address

1420 Peachtree Street, N.E.,
Suite 800
Atlanta, GA 30309-3053

Phones

1.404.581.8012 (Business Phone)

Faxes

1.404.581.8330 (Business Fax)

Emails

Contact Us (Business Email)

Websites

http://www.jonesday.com