Bradley Seltzer is a tax attorney in Holland & Knight's Washington, D.C., and Newport Beach offices. Mr. Seltzer brings more than 40 years of experience representing Fortune 100 utility, energy and telecommunications (telecom) clients in complex tax matters, including tax planning, accounting and controversy. He defends clients in large tax disputes with the IRS at the trial and appellate court levels, and prepares private letter rulings, technical advice requests and accounting method changes for the IRS.
Mr. Seltzer has extensive experience testifying at public hearings and providing written comments on behalf of clients regarding notices and proposed regulations that affect the utility industry, such as interest synchronization, consolidated tax adjustments, the normalization consequences of dispositions or deregulation, nuclear decommissioning issues, and incentives enacted as part of the Inflation Reduction Act (IRA). He also counsels on tax saving strategies, including qualifying for the tax incentives enacted as part of the IRA, and manages complex tax refund claims, audits, appeals and litigation. Mr. Seltzer also serves as an expert witness in federal and state ratemaking proceedings regarding deferred taxes, normalization and consolidated returns, and also assists client witnesses in preparing their testimony in such rate cases.
In addition, Mr. Seltzer is a frequent speaker on utility and telecom tax topics at various industry conferences as well as before various 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.
Prior to joining Holland & Knight, Mr. Seltzer was a tax partner for a global law firm in its Washington, D.C., office.
- 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:
- 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
- The George Washington University Law School, J.D., with high honors
- State University of New York at Albany, B.A., magna cum laude
- District of Columbia
- 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
- The Legal 500 USA, International Tax, 2017; U.S. Taxes: Contentious, 2017; U.S. Taxes: Non-Contentious, 2022