Jennifer R. Pusch

Jenny represents clients in all types of tax disputes and controversy, including federal and state audits, administrative appeals and litigation. She also advises renewable energy companies on federal tax credits, including credits expanded or created by the Inflation Reduction Act, and advises on state and local taxation of different renewable energy projects. 

Jenny assists her clients on a variety of tax matters, including the following:

• Tax Disputes & Litigation
  • State Corporate Income and Franchise Taxes, including nexus, Public Law 86-272, business versus non‑business income, apportionment, and federal preemption;
  • Federal Corporate Income Taxes, including trade or business expenses (e.g. reasonable compensation, travel, substantiation), penalty abatement (including accuracy-related penalties and fraud), and offshore financial asset disclosures;
  • Employment and Withholding Taxes, including worker classification audits and appeals, penalty abatement, withholding requirements for companies with international and nonimmigrant employees, and Form 5500 delinquent filings;
  • Sales and Use Taxes, including exemptions (e.g. direct mail, advertising, materials used to construct renewable energy facilities), nexus, sourcing, marketplace provider obligations, bundled transactions, and voluntary disclosures;
  • Individual Income Taxes, including passive/active loss issues, hobby losses, automated underreporting issues, offshore financial asset disclosures and streamline filings, exit tax, and collection matters.
• Renewable Energy Taxes, Jenny advises renewable energy developers (utility-scale wind and solar projects, community solar, transmission, storage, etc.) on state and local taxation, including preparing property tax modeling, transactional advice, and tax opinions. She also helps clients navigate conversations with local governments regarding the tax benefits of a project.
• Property Tax Appeals, including valuation and appeals of real and personal property (including commercial and state-assessed property). Jenny also advises clients on federal and state tax issues regarding conservation easements, including procedural and reporting issues.

Jenny serves clients from a variety of industries including, retail, construction, manufacturing, computer software, healthcare, financial services, restaurants, entertainment, energy, renewable energy and carbon credits. Additionally, Jenny represents pro bono clients on tax matters and immigration and asylum matters.

Education

• University of Wisconsin Law School, J.D., 2014
• Gustavus Adolphus College, B.A., 2009, magna cum laude

Admissions

• Minnesota, 2014
• Wisconsin, 2014
• U.S. Tax Court, 2020

Clerkships

• Judicial Law Clerk, Minnesota Tax Court, 2015-2017

• Best Lawyers: Ones to Watch, Tax Law, 2022-2024
• North Star Lawyer, Minnesota State Bar Association, 2019-2023

Professional Activities

• American Bar Association, Taxation Section
• Minnesota State Bar Association, Tax Law Section, Council Member 2021-present
• Member, Institute for Professionals in Taxation

Community

• Southern Minnesota Regional Legal Services (SMRLS), 2016-present
• Gustavus Adolphus College Mentoring Program, Mentor, 2016-2018