Overview
Bradley Seltzer advises Fortune 100 companies on complex tax planning, accounting and controversy matters, helping clients manage significant tax exposure, capture available incentives and resolve high-stakes disputes with the IRS. Based in Washington, D.C., and Dallas, he brings more than four decades of experience to the tax issues that shape regulated industries.
When tax positions are challenged, clients rely on Brad at every stage of a dispute. He defends clients in large tax disputes with the IRS at the trial and appellate court levels and manages complex tax refund claims, audits, appeals and litigation. He also prepares private letter rulings, technical advice requests and accounting method changes, helping clients obtain clarity from the IRS on difficult issues.
Brad also helps clients have a voice in the rules that govern their industry. He testifies at public hearings and submits written comments on behalf of clients regarding notices and proposed regulations affecting the utility industry, including interest synchronization, consolidated tax adjustments, the normalization consequences of dispositions or deregulation, nuclear decommissioning issues and incentives enacted under the Inflation Reduction Act (IRA). He counsels clients on tax-saving strategies as well, including qualifying for IRA tax incentives.
In utility ratemaking, Brad serves as an expert witness in federal and state proceedings on deferred taxes, normalization and consolidated returns. He also helps client witnesses prepare their testimony in rate cases so that complex tax issues are presented clearly to regulators.
A frequent speaker on utility and telecom tax topics, Brad has addressed industry conferences, trade associations and professional organizations, including the American Bar Association (ABA) Section of Taxation, Edison Electric Institute (EEI), American Gas Association (AGA), National Association of Regulatory Utility Commissioners (NARUC) and the IRS.
Before joining Holland & Knight, he was a tax partner in the Washington, D.C., office of a global law firm and a principal at a Big 4 advisory firm. His combination of IRS controversy experience, regulatory advocacy and ratemaking testimony gives clients an integrated perspective on tax issues that affect both their financial results and their regulatory standing.
Representative Experience
- Provided expert testimony on behalf of a Fortune 500 energy company in Federal Energy Regulation Commission (FERC) rate case regarding deferred tax assets
- Provided expert testimony on behalf of a Fortune 500 energy company in FERC rate case regarding consolidated returns and intercompany obligations
Assisted multiple clients with the following:
- Applications for Sections 48C and 45X tax credit allocations
- Qualification of renewable natural gas (RNG) projects for investment tax credit (ITC)
- Advice regarding offshore wind project tax credit eligibility
- Deductibility of contributions to California Wildfire Fund
- Normalization consequences of involuntary conversions
- Impact of tax sharing payments under normalization rules
- Compliance of ratemaking methods with consistency rules of normalization
- Proper accounting for year-end sales
- Taxation of customer deposits
Credentials
- The George Washington University Law School, J.D., with high honors
- State University of New York at Albany, B.A., magna cum laude
- California
- District of Columbia
- Texas
- U.S. Tax Court
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Court of Federal Claims
- U.S. Supreme Court
- Supreme Court of California
- American Bar Association (ABA), Section of Taxation, Section of Public Utility, Former Chair; Normalization and Industry Specialization Subcommittees, Former Chair
- District of Columbia Bar, Taxation Section, Steering Committee and Tax Policy Committee, Former Member
- Leading Global Tax Lawyers, Lawdragon 500, 2025, 2026
- The Legal 500 USA, International Tax, 2017; U.S. Taxes: Contentious, 2017; U.S. Taxes: Non-Contentious, 2022