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Madison Felder

Associate
Greenville | 864.577.6362
Fax | 864.242.9888
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Madison focuses his practice on state and local tax (SALT) and federal tax issues related to public finance transactions and economic development. His experience includes drafting fee-in-lieu of tax (FILOT) agreements, drafting infrastructure credit agreements, filing claims for refund, and applying for various tax incentives for economic development. His experience with public finance transactions includes working closely with municipal bond issuers and underwriters to monitor compliance with continuing disclosure requirements enforced by the Securities and Exchange Commission (SEC) under rule 15c2-12.

In addition, Madison assists clients with tax questions in a wide variety of areas, including tax controversy, tax planning, business incentives, and corporate formation. For example, he has represented businesses on income tax matters before the South Carolina Department of Revenue, property tax matters before local taxing authorities, and license tax matters before out-of-state regulators. He has also advised international clients on corporate law matters ranging from initial corporate formation decisions to buy-sell agreements to merger transactions.

While at the University of South Carolina, Madison served as a research editor for the American Bar Association's Real Property, Trust and Estate Law Journal and as a research assistant to professor Brant Hellwig. At the University of Florida, where he earned a master's in tax law, Madison served as a research assistant to professor Steve Willis.

Representative Experience

  • Assisted in representing a Fortune 500 company both during audit and during trial in the state’s Tax Court in seeking a refund of $5 million of corporate income tax due to the state’s improper taxation of exempt federal interest income in violation of the United States Constitution.
  • Assisted in representing a Fortune 500 company in obtaining a settlement involving disputed nexus, disputed sourcing of income, and disputed years subject to tax with settlement terms favorable to the client and presenting no penalties for non-filing and non-payment of taxes for prior years.
  • Assisted in representing a Fortune 100 company by successfully negotiating a settlement with a state taxing agency seeking $125 million in license fees and corporate income taxes. The taxing agency sought nexus over banks, credit card companies, and securitization companies plus the taxing agency sought to apportion taxable income using a “market based” apportionment (based on the location of the customer) rather than a cost of performance basis.

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