Christopher R. Duggan
PEOPLE

Christopher R. Duggan

Of Counsel
duggan.chris@dorsey.com

Overview

CHRIS HELPS CLIENTS RESOLVE FEDERAL, STATE AND LOCAL TAX PROBLEMS AND SPECIALIZES IN ASSISTING COOPERATIVE ASSOCIATIONS WITH THEIR UNIQUE TAX ISSUES.

A senior attorney in Dorsey’s Tax Group, Chris advises clients, including e-commerce and international retailers, on minimizing state and local income, sales and use, excise, and business and occupation tax exposure. Chris also assists clients with federal tax issues, audits and appeals, and has special expertise in Section 1031 exchanges, federal excise taxes, and federal tax credits, such as the New Markets Tax Credit.

For over 15 years, Chris has advised and assisted cooperative associations with tax issues relating to cooperative operation and distributions, restructurings, recapitalizations, mergers and joint ventures. Chris has also assisted clients in converting to and from cooperative status.

Education & Admissions

William Mitchell College of Law (J.D., 2000), summa cum laude; Editor, William Mitchell Law Review, 1999-2000

Northwestern University (Ph.D., British and Early Modern European History, 1993)

University of Minnesota (B.A., History, 1985), summa cum laude

Admissions

  • Minnesota
  • U.S. District Courts for the District of Minnesota, the Western District of Michigan, and the Eastern District of Wisconsin
  • U.S. Court of Appeals for the Sixth Circuit

Experience

  • Tax structuring for e-commerce website making direct, drop-shipment, and third-party sales.
  • IRS appeal permitting telephone cooperative to treat gain from sale of telecommunications company stock as patronage-sourced income.
  • Tax opinions on New Market Tax Credit financings for dairy cooperative, manufacturer, nursing home, nonprofit youth shelter and several school districts.
  • Recapitalization of cooperative involving exchange of patrons’ equities for preferred stock.
  • Conversion of mining corporation into a single-member cooperative.
  • Conversion of limited liability tire products company into cooperative.
  • Conversion of biodiesel cooperative into limited liability company.
  • Merger of two blood supply cooperatives.

News & Resources

Articles

U.S. Supreme Court Hands Down Two Significant Tax Decisions
New Tax Act
“Minnesota Supreme Court Holds St. Paul. Right-of-Way Charges are Taxes,” State Tax Notes, Jan. 23, 2017, at 367 (with Sarah E. Claypool)
“NCFC Requests IRS Guidance on the Application of IC-DISC Rules to Farmer Cooperatives,” The Cooperative Accountant (Winter 2016)
“Rolling Stock: The Hidden Exemption to Minnesota Sales and Use Tax,” State Tax Notes, June 6, 2016, at 763
Cooperative Business Law: A Practical Guide to the Special Laws Governing Cooperatives
Tax chapter in Michael Droke et al., Cooperative Business Law: A Practical Guide to the Special Laws Governing Cooperatives, 2d Ed. (Minneapolis: Dorsey & Whitney LLP, 2014)
“Latest Ruling on Capital Credit Discount Plan of 501(c)(12) Cooperative: P.L.R. 201423027,” The Cooperative Accountant (Winter 2014)
“Section 501(c)(16) Crop Financing Corporations, Marijuana Growers and PLR 201333014 (May 20, 2013),” The Cooperative Accountant (Winter 2013)
"Chief Counsel Advice 201228035: A Critique," The Cooperative Accountant (Fall 2013)
Congress Passes H.R. 8, the American Taxpayer Relief Act, and Averts the “Fiscal Cliff”
"Property Owners Beware: The Minnesota Supreme Court has Twice Misconstrued Express Easements," 25 Wm. Mitchell L. Rev. 1545

News & Press Mentions

Dorsey & Whitney Represents CHS Inc. in Public Offering of Preferred Stock

Events & Speaking Engagements

NCFC Annual Meeting - Legal, Tax & Accounting Conference

Select Presentations

  • Co-presenter, "Litigation Update" at National Intertribal Tax Alliance Annual Conference in Prior Lake, Minnesota, August 2006
  • Co-presenter, “Litigation Update” at National Intertribal Tax Alliance Annual Conference in Albuquerque, New Mexico, September 2004
  • Co-presenter, “State Taxation in Indian Country,” and “IRS Developments Involving Tribal Tax-Exempt Financings and Other Tribal Matters” at Dorsey & Whitney LLP Workshop on “Current Tax Issues Facing Tribes: Practical Solutions and Opportunities” in Seattle, February 2003    
  • Co-presenter, “Louisiana Taxation in Indian Country” at the Louisiana-Tribal Tax Summit, a gathering of Louisiana and tribal officials in Kinder, Louisiana, November 2002   

Industries & Practices

  • Banking & Financial Institutions
  • Closely Held Businesses
  • Cooperative Law
  • Food, Beverage & Agribusiness
  • Healthcare
  • Indian & Alaska Native
  • Mining
  • Tax
  • Tax Controversy & Litigation
  • Technology

Professional & Civic

Professional Achievements

  • Regular Contributor, TAXFAX section of The Cooperative Accountant
  • Member, National Society of Accountants for Cooperatives
  • Member, Minnesota Bar Association
  • Member, National Council of Farmer Cooperatives
  • Member, American Historical Association
  • Member, Selden Society for Study of the History of English Law

Accolades

  • MSBA North Star Lawyer, 2012
Christopher R. Duggan