CLIFF JERNIGAN

Author and Consultant

Law Office of Cliff Jernigan
Woodside, California, USA

Law Firm - National

Professional Summary

Cliff Jernigan is a long-time member of the California bar, with a law degree from Hastings College of the University of California and an advanced tax law degree from New York University Law School. He has been associated with a New York City international law firm and has held corporate tax counsel positions in the areas of banking, chemicals, food and real estate, and semiconductors, where he was Director of Tax and Global Public Policy for AMD. His last position was as a US Treasury Department appointee in the senior management of the IRS in the Large and Mid-Size Business Division, where he advised management on the major issues of the telecommunications, high-technology and media industries.

Jernigan has been a leader in promoting positive relationships between industry and the IRS. He was a founder and first president of the Santa Clara Valley Chapter of the Tax Executives Institute, the founder/director of the Silicon Valley Tax Directors Group, the Chair of the Tax Committee of the American Electronics Association, and the Chair of the Semiconductor Industry Association.

For many years he was a part-time business school adjunct assistant professor at Golden Gate University and an instructor in the Graduate Tax Program at San Jose State University.

Jernigan has written three books. Two of the books dealt with the topic of international trade issues for the high-technology industry. The last book describes his experiences during his appointment to the IRS.

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Languages

  • ENGLISH

Industry Experience

    • Law Firm
    • Semiconductors
    • Food and Real Estate
    • Chemical
    • Banking
    • Law Firm

Interests/Hobbies

  • International travel,food and wine--own vineyard and produce award-winning Cabernet Sauvignon by name of Olive Hill Lane Press
  • Golf
  • Swimming

Birthday

April 30

Experience

Law Office of Cliff Jernigan
Woodside, California, USA 94062
Author and Consultant
Law Firm - National
2005 - Present

In addition to his tax and legislative practice, Jernigan has been the author of three books:

High Tech Survival--The Impact of Government on High Tech and Biotech Companies, 1996--Olive Hill Lane Press

Beyond High Tech Survival--Turning Government Policy into International Profits--1998--Olive Hill Lane Press

Corporate Tax Audit Survival--A View of the IRS through Corporate Insider Eyes--2005--Olive Hill Lane Press

The first two books dealt with Jernigan's experiences on the leading edge of government policy reforms for the semiconductor industry in the areas of tax, trade, intellectual property, antitrust, export controls, tariffs, environmental issues, immigration, and workforce issues.

The last book--Corporate Tax Audit Survival- A View of the IRS through Corporate Insider Eyes-dealt with the author's experiences in the senior management of the IRS for the four-year period from 2001-2005. While having considerable experience engaging in audits with the IRS, it was quite another thing to be part of the IRS as a US Treasury Department four-year term appointee to improve the IRS in the areas of customer interaction, efficiency, and audit effectiveness. As someone from industry, he was not always trusted by many in the IRS, especially the field examiners. In the book he imparts his many insights into the ways people in the IRS think, act, and perform their jobs. He also describes to practitioners how they can be more effective in their audits with the IRS.

Large and Mid-Size Business Division of IRS
San Jose, California, USA
Senior Industry Advisor--Telecom, High Tech, Media
2001 - 2005
U. S. Treasury Department Four-Year Appointee to the Senior Management of the IRS. Advised IRS management about the nature and workings of the telecommunications, high tech (hardware and software) and media (movie, music recording, gaming, sports teams, and sports leagues) industries. Helped resolve contentious issues among the industries and the IRS. Worked to develop better relations between industry and the IRS. Helped devise programs to reduce audit time and audit efficiency for industry.
AMD
Sunnyvale, California, USA
Director of Worldwide Government Affairs
Corporation - Publicly-Held
1984 - 2001
Formed government affairs function in 1984. Was principally engaged in federal, state and international government affairs issues, including helping to introduce federal and state tax legislation helpful to the semiconductor industry (faster depreciation write-offs, R & E credit, easier FISC qualification, foreign tax credit carryover and carryback periods, stock options), working with the Semiconductor Industry Association and the American Electronic Association to gain access to foreign markets (principally in Japan, Korea, China, Russia, and the European Union) through market opening efforts with the U.S. Trade Representative and the US Department of Commerce, keeping a vigilant eye on foreign country dumping of goods in the US (Japan, Korea, China, European Union)by working to impose anti-dumping and countervailing duties on offenders, leading the industry effort to enact US antitrust laws enabling US competitors to join in joint research and manufacturing activities, protecting intellectual property rights of AMD and the industry through aggressive legislation (Semiconductor Chip Protection Act)and other enforcement measures, participating in industry efforts to lower worldwide tariffs on semiconductor products, helping industry lessen the impact of onerous US export control laws, and dealing with environmental, immigration (H-1B visas), frivolous securities lawsuits, and various stock option and other compensation issues.
AMD
Sunnyvale, California, USA
Director of Worldwide Taxes & General Tax Counsel
Corporation - Publicly-Held
1979 - 1984
Formed AMD tax department in 1979 and grew department to 13 lawyers, accountants and clerical staff through 1984. Main areas of emphasis were to research and plan corporate tax positions for domestic and international operations, to oversee the filing of complete and accurate federal, state, foreign and local tax returns, to successfully engage in efficient, effective and cost saving tax audits, and to maximize cash flow and the financial impact of tax planning on the corporate financial statements. Planned overseas tax structures with respect to Subpart F and CFC rules, foreign tax credits, supportable intercompany transfer pricing, forming of DISC and FISC, coordination of disparate US and tax foreign laws, use of rapid depreciation rules for domestic operations, planning for the R & E and investment tax credits, recovering custom duties through drawback programs, setting up company profit sharing and TRASOP plans, advising on stock option plans, planning for the taxation of US citizens abroad and nonresident aliens, and working with the finance group to set the tax provisions for quarterly and annual reports. Active in outside industry groups, including TEI, the San Francisco International Tax Group and the American Electronic Association. Formed Silicon Valley Tax Conference (ultimately evolving into the Santa Clara Valley TEI, of which I was the first president) and the Silicon Valley Tax Directors Group, which I directed for 20 years.
Castle and Cooke
San Francisco, California, USA
Manager, Tax Research and Planning
Corporation - Publicly-Held
1976 - 1979
Managed worldwide tax research and planning function with one associate tax lawyer. Responsible for Subpart F and CFC planning for subsidiaries in Europe, Asia and South America. Actively involved in the acquisition of companies and assets in Europe and South America. Involved in DISC, FISC, Western Hemisphere Trade Corporation, Section 936 companies and Section 957(c) (Puerto Rico). Worked closely with US and foreign outside law and accounting firms to effect best results for company. Involved with investment tax credit issues, including the applicability of the investment tax credit to mushroom growing houses (ultimately helped to gain favorable legislation in this area), and the special rules for domestic shipping operations (interplay of DISC with capital construction fund rules).
Stauffer Chemical Company
San Francisco, California, USA
Manager, Tax Research and Planning
Corporation - Publicly-Held
1973 - 1976
Managed three attorneys and one clerical staff person. Responsible for worldwide tax research and planning, including the effective use of Subpart F, CFCs, foreign tax credits, DISC, FISC, domestic and foreign sales and plant site selection, with considerable emphasis on supportable intercompany transfer pricing, investment tax credits, including the formation of a 1% ITC Thrift Plan, rapid depreciation, depletion of minerals, and drafting of the company profit-sharing plan.
Bank of America
San Francisco, California, USA
Assistant Tax Counsel
Corporation - Publicly-Held
1970 - 1973
Assistant Tax Counsel to the Bank of America at its world headquarters in San Francisco. Deep involvement with the planning of the foreign tax credit as it impacted international loans, forming of the Bank's DISC, utilization of foreign tax credits by maximizing foreign source income, forming BA Leasing Corporation in 30 states to handle all of the Bank's major leasing operations (advised on tax, legal and accounting issues and was corporate secretary), helped with the taxation of US citizens abroad and nonresidents in the US, involved in proposed insurance company, and performed routine tax research in all areas, including foreign, tax treaties, federal, state and local.
Boyd & Holbrook
New York, New York, USA
Attorney
Law Firm - International
1968 - 1970
Researched tax and other legal issues for law firm partners. Formed corporations, drafted articles of incorporation and by-laws, wrote minutes, dissolved and liquidated corporations. Worked with Finnish and Swedish clients to mesh their US and foreign country tax obligations. Worked on SEC filings and immigration visas. Prepared US Citizens Abroad tax returns.

Education

LLM, Taxation, with emphasis on international taxation 1970
New York University School of Law, Masters in Tax
New York City, New York, United States
JD1968
University of California, Hastings College of the Law
San Francisco, California, United States
BS, History, with minor in English 1964
University of Oregon
Eugene, Oregon, United States

Professional Certifications

California Bar
1969
Inactive

Bar Admissions

California
Inactive
1969

Court Admissions

  • US Tax Court
  • California Supreme Court

Associations and Societies

  • Tax Executives Institute (First President of Santa Clara Valley Chapter)
  • Silicon Valley Tax Conference (Founder)
  • Silicon Valley Tax Directors Group (Founder and director from 1982-2001)
  • Semiconductor Industry Association (Head of Tax Committee (84-01) and Legal Committee (01))
  • American Electronics Association (Head of Tax Committee--1986-1987)
  • San Francisco International Tax Group (first group) (member--1976-1981)
  • San Francisco Bar Association (Member--1970-1979)

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