Christopher J. Sullivan
Shareholder and President

Christopher J. Sullivan, Esq., is the President of Rath Young Pignatelli and serves on its Management Committee. Chris’ practice focuses on multi-state taxation representing clients in forums ranging from administrative agencies and court rooms to the Legislature. Chris represents corporate clients in tax matters before the New Hampshire Department of Revenue Administration, the Massachusetts Department of Revenue, and the Vermont Department of Taxes, and advises companies on multi-state matters involving states across the country. His representation includes creating value for clients during the audit, assessment and refund process for in-state and multi-state companies as well as representing corporate clients in economic development efforts choosing to locate jobs and business in the Granite State. He has devoted substantial time to nexus, apportionment and reasonable compensation issues, combined reporting issues, and the treatment of foreign source income. While other states are only recently considering or adopting combination, New Hampshire has utilized unitary combination since 1986. He works on matters involving the New Hampshire Business Enterprise Tax, Business Profits Tax, the Real Estate Transfer Tax, Interest and Dividends Tax, the Meals and Rentals Tax and Real Property Tax. He regularly advises companies regarding voluntary disclosure agreements, particularly due to accounting reserve standards FIN 48 and increased jurisdictional aggressiveness in the multi-state arena. Chris has been consistently recognized by Best Lawyers in America and in 2019 was named Lawyer of the Year, Tax Law. Chris is a nationally-recognized speaker on state tax issues. He writes articles for State Tax Notes and regular updates for the Council on State Taxation and teaches frequently on New England Tax issues. In 2016, Chris was featured in State Tax Today’s Spotlight. Chris was a founder and serves as the Treasurer of the New England State and Local Tax Forum, which expands education on multistate tax issues for New England companies and practitioners. Chris also serves on the Board of Trustees of the NYU Institute on State and Local Taxation. Appointed by the Senate President, he served on New Hampshire’s Study Commission on Apportionment on potential business tax reform and New Hampshire’s competitive position compared to other states. Chris is an honors graduate of Harvard College and Georgetown University Law Center.

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Education and Bar Admissions

Education:

  • Georgetown University Law Center, J.D., cum laude, 1996
  • Harvard College, B.A., cum laude, 1989

Bar Admissions:

  • New Hampshire
  • Massachusetts
  • Vermont
Awards and Recognitions
  • New England State and Local Tax Forum, Board of Directors and Treasurer
  • Practitioner Partner, Council on State Taxation (COST)
  • Commissioner, New England Association of Schools and Colleges, Inc., Commission on Institutions of Higher Education 2008-2014
  • Commissioner, New Hampshire Postsecondary Education Commission, 2001 – 2006
  • Advisor to Gov. John Lynch, New Hampshire 2004-2005
  • Member, Platform Committee and Executive Committee, New Hampshire Democratic Party, 2000 – 2005
  • Delegate, Democratic National Convention, 2000


Best Lawyers Award Badge


Best Lawyers Award Badge

Community Involvement
  • Trustee, Concord Community Music School, 2008-2014
  • Member, Board of Directors, Concord Little League, 2008-2010, 2013-Present
  • Coach, Concord High School Girls Track and Field, 2000 – 2006
  • Member, Board of Directors, Friends Program, Inc., 1998-2004; President, 2002-2003
Noteworthy
  • Chris Sullivan will co-present “Don’t Get Caught In the Ethics Web – Maneuvering Around Sticky Salt Issues In A Technological World” at the 38th Institute on State and Local Taxation held in New York, NY (December 16-17, 2019).
  • Chris Sullivan will co-present “Top Issues in New England SALT” at the 8th Annual New England State and Local Tax Forum (November 20, 2019).
  • Chris Sullivan presented “Income Tax Concepts in a Sales Tax World” at the IPT Sales Tax Symposium held in Indian Wells, CA (September 30-October 3, 2018).
  • Chris Sullivan co-presented “Hey ’19! A Year in Review” at the IPT Sales Tax Symposium held in Orlando, FL (September 22-September 25, 2019).
  • Chris Sullivan co-presented “Tax Case Roundup – Significant Litigation Over the Past Year” at the IPT State Income Tax Symposium held in Orlando, FL (January 13-16, 2019).
  • Chris Sullivan co-presented “Audit Issues: Sales Tax & Income Tax” at the NYU 37th Institute on State & Local Taxation held in New York, NY (December 17, 2018).
  • Chris Sullivan presented “Income Tax Concepts in a Sales Tax World” at the IPT Sales Tax Symposium held in Indian Wells, CA (September 30-October 3, 2018).
  • Chris Sullivan co-presented “Surviving Alternative Apportionment” at the COST 2018 Spring Audit Session & Income Tax Conference held in Boston, MA (April 17-20).
  • Chris Sullivan co-presented “Square Pegs in Round Holes: What Every Seller and Purchaser Should Know About Sales Taxation of Digital Goods and Cloud Computing” at the 2018 ABA/IPT Advanced Tax Seminar held in New Orleans, LA (March 19-23).
  • Chris Sullivan co-authored “The State of the States: State Tax Issues Impacting Businesses in NH”; published in the February 21, 2018 edition of the New Hampshire Bar News.
  • Chris Sullivan co-presented “Corporate Governance Perspectives on Controversy” at the 2018 National Multistate Symposium held in Orlando, FL (February 7-9, 2018).
  • Chris Sullivan co-presented “Current Audit Issues – A Practical Guide for Controversy Resolution” at the NYU School of Professional Studies 36th Institute on State and Local Taxation held in New York, NY (December 4-5, 2017).
  • Chris Sullivan co-presented “Filling out the Map: New England Combined Filing” at the NE SALT Forum held in Newton, MA (November 15, 2017).
  • Chris Sullivan co-presented “The SALT Academy Awards” at the 2017 COST 48th Annual Meeting held in Orlando, FL (October 22-25, 2017).
  • Chris Sullivan presented “Discussion of the State Tax Cases and Issues” at the 2017 COST North Atlantic Regional State Tax Seminar in Waltham, MA (June 22, 2017).
  • Chris Sullivan co-presents “North of the Border:  The NH Tax System and Top Mistakes to Avoid” at the Boston Bar Association’s State and Local Tax Committee (March 7, 2017)
  • Chris Sullivan presents “Discussion of State Tax Cases, Issues & Policy Matters to Watchat Council on State Taxation’s North Atlantic Regional State Tax Seminar in Hartford, Connecticut (December 10, 2015)
  • Chris Sullivan presents “Top Issues in New England SALTat New England State and Local Tax Forum in Newton, MA (November 16, 2015)
  • Chris Sullivan presents “Multistate Apportionment” at the 33rd Annual Tax Forum sponsored by the New Hampshire Society of CPSs and the New Hampshire Bar Association in Concord, NH (November 5, 2015)
  • Chris Sullivan presents “The State of So-Called Tax Havensat the Paul J. Hartman State & Local Tax Forum in Nashville, Tennessee (October 27-29, 2015)
  • Chris Sullivan co-presents “Jurisdiction to Tax: Constitutional and Federal Constraints” at NYU’s Summer Institute in Taxation, NYC, NY (July 13, 2015).
  • Chris Sullivan presents “Discussion of State Tax Cases, Issues & Policy Matters to Watch”, COST North Atlantic Regional State Tax Seminar, Waltham, MA (May 5, 2015)
  • Chris Sullivan co-presents “State Taxation of Pass-Through Entities: Key Issues and Current Developments” at The Chicago Tax Club, Oak Brook, IL (April 13, 2015)
  • Chris Sullivan co-presents “Economic Presence  Does Not Negate P.L. 86-272:
    A Re-Examination of Protected and Unprotected Activities in a Digital Age” at the 2015 ABA/IPT Advanced Income Tax Seminar, New Orleans, LA (March 16-18, 2015)
  • Chris Sullivan co-presents “Exploring Proactive State Resolutions – VDA’s, Amnesty, and Alternative Apportionment” at Deloitte’s 2015 National Multistate Tax Symposium, Lake Buena Vista, FL (February 4-6, 2015)
  • Chris Sullivan co-presents “National SALT Update” at the New England State and Local Tax Forum, Newton, MA (November 2014)
  • Chris Sullivan co-presents “Market-Based Apportionment-What does it mean for NH businesses?” at the NHBA-NHSCPA’s 32nd Annual Tax Forum, Concord, NH (November 2014)
  • Chris Sullivan presents “Unity in the “Real World” – Practical Considerations in Building a Unitary (or Non-Unitary) Case at COST’s 45h Annual Meeting, Hollywood, FL (October 2014)
  • Chris Sullivan co-presents “Massachusetts 2014 Tax Change to “Market-Based Sourcing,” New Hampshire Business & Industry Association, Economic Development and Fiscal Policy Committee (May 9, 2014)
  • Chris Sullivan and Professor Rick Pomp present, “National SALT Case Update” at New England State and Local Tax Forum in Newton, MA. (November 15, 2013)
  • Chris Sullivan and Bill Ardinger present, “The Impact of Federal Legislative Developments on State and Local Taxes Affecting NH Business” at 31st Annual Tax Forum in Concord, NH. (October 31, 2013)
  • Chris presents “Top Ten Cases in Sales and Use Tax” at Paul J. Hartman State and Local Tax Forum in Nashville, TN. (October 28, 2013)
  • Bill Ardinger, Chris Sullivan and Kathryn Michaelis, present, “2013 Massachusetts Tax Law Changes – Impact on NH Tech Industry”, NH High Tech Council (October 9, 2013).
  • Chris Sullivan presents “New Hampshire Property Tax Issues for Private Schools” at ISANNE’s Business Associates Annual Conference, Mt. Washington Hotel, Bretton Woods, NH. (January 7-9, 2013)
  • Chris Sullivan presents “Overview of New Hampshire Taxation” to the Nashua Chamber of Commerce Legislative Symposium, Nashua NH. (January 7, 2013)
  • Chris Sullivan presents “Best Practices for Settling a State Tax Dispute and Knowing When to Extend the Statute of Limitations” at TEI’s State and Local Tax Controversy Seminar, Orlando, Florida (December 6-7, 2012).
  • Chris Sullivan presents “State Tax Issues to Consider in Buying and Selling a Closely-Held Business” and “The Real Estate Transfer Tax: What Now?” at NH Bar Association’s 30th Annual Tax Forum, Concord, NH (November 30, 2012).
  • Chris Sullivan presents “Steps for a Successful Audit (and Common Mistakes)” at New England SALT Forum, Needham, MA (November 15, 2012).
  • Chris Sullivan co-presents “Discussion of State Tax Cases and Issues to Watch in 2012 & Beyond,” COST North Atlantic Regional State Tax Seminar, Waltham, MA (October 2, 2012).
  • Chris Sullivan presents “State and Local Multistate Taxation (SALT): A Dash of Theory and Practice” at Vermont Tax Practitioners Association, Montpelier, VT (September 18, 2012).
  • New Hampshire Magazine, “Tomorrow’s Lawyer Today”, 2003
  • Author–New Hampshire Tax Developments, Council on State Taxation, 1998 – Present.
  • Author–New Hampshire Tax Developments, The ABA State and Local Tax Lawyer, 2001 – Present.
  • Author–New Hampshire Property Tax, The ABA Property Tax Deskbook, 2003 – Present.

Clerkships

  • Chris served as law clerk for Judge Paul Barbadoro, United States District Court of the District of New Hampshire, 1996-1997