Our Website Uses Cookies
We and the third parties that provide content, functionality, or business services on our website may use cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, on and off the website, and help us understand your interests and improve the website.
For more information, please contact us or consult our Privacy Notice.
Your binder contains too many pages, the maximum is 40.
We are unable to add this page to your binder, please try again later.
This page has been added to your binder.
Jeremy Spector’s practice involves tax planning, IRS controversy work, and the structuring of corporate transactions, with particular emphasis on advising professional sports leagues and teams and on representing large taxpayers through the IRS audit, Fast Track, and Appeals processes.
Mr. Spector has been ranked as a leading tax expert in the Legal 500 US for his “superb legal advice and practical business guidance," and by Chambers USA, which has noted his practice’s “dominant presence in the sports industry.”
Representative clients in the sports world include the National Football League, Major League Baseball, the National Basketball Association, the National Hockey League, Major League Soccer, the UFC, Fenway Sports Group, the United States Olympic Committee, and dozens of professional sports clubs.
Mr. Spector's sports-related work encompasses such matters as the purchase and sale of sports franchises, public and private stadium financing, player compensation, the relationship between taxable and tax-exempt entities, franchise and network valuations, and the treatment of sponsorship, licensing, and broadcast agreements.
He has successfully represented clients at the IRS Examination and Appeals levels and in securing rulings from the IRS National Office on all the foregoing issues, as well as on the following topics: changes in accounting methods and periods, capitalization of tangible and intangible assets, deductibility of government fines, treatment of fringe benefits, and allowability of the Section 199 deduction.
He also has significant experience counseling clients in the communications and media space on both transactional and controversy matters, and has advised clients such as Amazon.com, Sotheby’s, and Yahoo! regarding the federal and state taxation of e-commerce and similar multi-jurisdictional transactions.
- Secured a “no change” letter from the IRS Examination division after its challenge to the economic substance of a taxpayer’s $1.1 billion financing program.
- Settled an Appeals case regarding a franchise owner’s built-in gain upon the sale of his franchise, with the taxpayer receiving a multi-million dollar refund from the government.
- Advising the National Hockey League on domestic and cross-border tax, corporate, and intellectual property issues related to the creation of the NHL Network, and, separately, the NHL’s business activity outside North America.
- Representation of an MLB club in a $300 million dispute with the IRS regarding the club’s affiliated cable network.
- Currently representing approximately a dozen professional sports franchises in IRS audits.
Tax Controversy Matters
- Persuaded a state Department of Taxation to reverse its long-held, industry-wide position regarding sports clubs’ apportionment methodologies and to consequently drop 14 separate club audits.
- Representation of an NFL club in a $275 million dispute with the IRS regarding stadium financing, player contracts, and broadcast agreements.
- Obtained reversal of an IRS Chief Counsel Advice memorandum regarding the tax treatment of a league-wide disability insurance program.
- Lobbied the Treasury Department on a client’s fringe benefit issue, resulting in an example being inserted in new regulations adopting the client’s facts and proposed legal conclusion.
- Secured “no change” letters in income tax audits of two sports leagues and three leagues’ for-profit affiliates (five separate audits).
- Negotiated an extremely favorable industry-wide settlement with the IRS National Office regarding the tax treatment of acquisitions of professional sports franchises and related assets.
- Successfully resolved Fast Track appeal of a communications company’s tax treatment of a governmental fine, based on a novel legal theory and resulting in the deductibility of the majority of the fine.
Tax Planning Matters
- Structuring John Henry’s sale of the Florida Marlins and his simultaneous acquisition (as lead investor) of the Boston Red Sox, Fenway Park, and NESN as a tax-free like-kind exchange.
- Representation of multiple NFL clubs regarding their respective billion-dollar stadium development projects. Issues include structuring club and league real estate and financing transactions, use of tax-exempt bond financing and personal seat licenses, coordination among affiliated taxable and tax-exempt entities, and counseling on transaction documents (leases, management agreements, etc.).
- Representation of the NFL and other sports leagues in tax, corporate, legislative, and PR matters related to the relinquishment of their tax-exempt status. Projects involved tax planning, meetings with IRS executives and members of Congress, and coordination of audit defense strategy.
- Advising Roush Fenway Racing on driving and endorsement agreements with Cup Series drivers, and advising Major League Soccer on marketing deals with its players.
- Advice regarding franchise transfers, including Chris Cohan’s sale of the Golden State Warriors, the NHL’s purchase and sale of the Phoenix Coyotes, Major League Baseball’s relocation and sale of the Montreal Expos, Fenway Sports Group’s purchase of a 50% interest in Roush Racing, and the USTA’s acquisition of the Western & Southern Financial Group Masters tournament.
- Drafting World Baseball Classic agreements with leagues, federations, venues, and players.
- Counseling clubs and all five leagues on crafting and drafting bonus and deferred compensation arrangements for players and front-office executives, including with respect to Section 409A issues.
- Representation of the NBA, NHL, and NFL regarding their pre-season, season-opening, and other regular season games in Europe, including the foreign tax consequences to players and teams.
- Establishing multi-entity, multi-jurisdictional organizational structures for leagues’ taxable and tax-exempt activities, including charities and foundations.
- Continuing advice to Sotheby’s on the sales and use tax ramifications of auctions.
- Legislative and strategic advice to Amazon.com regarding the state taxation of online sales.
- Advice to various broadcast stations and their private equity owners regarding station acquisitions and related marketing agreements.
Pro Bono
- Foundation for All DC Families, Catholics for Equality, Marylanders for Marriage Equality, and Human Rights Campaign – Tax and corporate advice to these organizations that engage in both non-partisan research regarding same-sex marriage and legislative advocacy supporting marriage equality.
- Funders Together to End Homelessness – Tax and corporate advice to this entity that serves as a national network of philanthropic funders.
- Community Tax Aid, Inc. – Representation of the Board of Directors of this low-income tax clinic in front of the IRS regarding a federal grant received by the organization.
- Georgetown Children’s House Endowment and Washington Child Development Council – Tax, governance, and general programmatic advice to these organizations that promote quality child care and childhood development in the District of Columbia.
August 14, 2018, Covington Alert
New restrictions on the deductibility of certain payments will require companies facing government investigations to pay close attention to the tax treatment of any settlement or court judgment, and to address this treatment in their negotiations with regulatory agencies. There is a risk under new tax rules that the amount paid to resolve these disputes may be ...
Sports Group Of The Year: Covington & Burling
February 5, 2018, Law360
Covington was named a 2017 Sports Practice Group of the Year by Law360. According to Ben Block, one of the most rewarding aspects of the sports group is the opportunity to work with repeat clients. "But," he adds, "every year and every day is a new, different, and exciting challenge." Commenting on the Tax Court victory on behalf of the Boston Bruins in a ...
Four Covington Partners Named Law360 MVPs
December 20, 2017
WASHINGTON—Law360 has named four Covington partners as MVPs in their respective practice areas. The awards single out lawyers from across numerous practice areas based on their success in high-stakes litigation, complex global matters, and record-breaking deals. The Covington lawyers recognized as Law360 MVPs are: Ray Biagini, Government Contracts. Mr. ...
MVP: Covington's Jeremy Spector
December 15, 2017, Law360
Jeremy Spector was named a 2017 Tax MVP by Law360. The publication emphasizes his unique practice which focuses on representing the sports industry, and highlights his "precedent-setting" victory on behalf of the Boston Bruins at the U.S. Tax Court.
June 29, 2017, Covington Alert
In a case that could have wide-ranging effect across the sports industry and potentially beyond, the U.S. Tax Court ruled on June 26, 2017, that the Boston Bruins were allowed to deduct 100 percent of the costs of meals that they served to their players and other employees at hotels while traveling for road games. The IRS had argued that only 50 percent of those ...
February 3, 2016
WASHINGTON, DC — Covington assisted the National Football League in negotiating its partnership with CBS and NBC to produce and televise "Thursday Night Football" for the 2016 and 2017 seasons. In addition to continuing its Thursday Night Football partnership with CBS, the NFL is adding NBC as a partner, with both networks set to air five Thursday Night Football ...
Conversations: Jeremy Spector
January 27, 2015, Tax Notes
Covington's Jeremy Spector is profiled in this article on his sports tax practice: "Jeremy Spector is a different sports fan than most — and with good reason. Spector, 44, an attorney with Covington & Burling LLP in Washington, is the lead tax counsel for Major League Baseball, the National Football League, the National Basketball Association, the National ...
November 26, 2013
WASHINGTON, DC, November 26, 2013 — Covington & Burling advised the National Hockey League in negotiating its twelve-year, C$5.2 billion agreement with Rogers Communications for national broadcast and multimedia rights to NHL games, including the Stanley Cup Playoffs and the Stanley Cup Final, in Canada. The agreement is the largest media rights deal in NHL ...
Domestic Exam Issues: An End-to-End Discussion of Hot Topics
April 17, 2013, TEI IRS Audits and Appeals Conference
LB&I Restructuring: What You Need To Know
10/30/2012) (discussion of new IRS audit techniques and audit defense strategies, TEI Annual Conference
April 13, 2012
WASHINGTON, DC, April 13, 2012 — Covington & Burling advised Tom Benson, the longtime owner of the New Orleans Saints, in his purchase of the New Orleans Hornets for an undisclosed sum. The purchase and related agreements were finalized this week. Closing is expected before the end of June. “I am very grateful to Bruce Wilson and the Covington team,” Mr. ...
Covington Advises NFL on Major Network TV Deal
December 15, 2011
WASHINGTON, DC, December 15, 2011 — Covington advised the National Football League in negotiating nine-year extensions of its Sunday broadcast television packages with CBS, FOX and NBC networks. The NFL owners voted to approve the package of TV deals with FOX, CBS and NBC on Wednesday. The new agreements, announced yesterday, run through the 2022 season, and ...
Covington Advises NFL in its Eight-Year Extension of Monday Night Football Rights with ESPN
September 9, 2011
WASHINGTON, DC, September 9, 2011 — The National Football League has announced that it has entered into a new eight-year agreement with ESPN providing for Monday Night Football, the most successful series in sports media history, to remain on ESPN through the 2021 NFL season. The broad multiplatform agreement, which begins in 2014, includes eight full seasons of ...
September 29, 2010, Covington E-Alert
July 15, 2010
WASHINGTON, DC, July 15, 2010 — Covington & Burling LLP is pleased to announce the signing of a Purchase Agreement for the sale of the Golden State Warriors, the NBA franchise based in Oakland, California, to an investor group led by Kleiner Perkins Caufield & Byers Managing Partner Joe Lacob and Mandalay Entertainment Group Chairman Peter Guber. The sale price ...
- Law360, Tax MVP (2017)
- Chambers USA, Sports Law (2014-2015)
- Legal 500 US, Tax - US Taxes (2013-2017)
- Legal 500 US, Not-for-Profit (2013-2017)
- Legal 500 US, Sports (2014-2016)
- Legal 500 US, Tax: Tax Controversy (2012, 2014-2015)
- Legal 500 US, Telecoms and Broadcast: Transactional and Tax (2012)