Eric S. Tresh

• Representing Charter Communications in 10 years of central assessment litigation. The Court recently denied the State’s motion to dismiss. Matter remains pending.
• Represented amici before the US Supreme Court in several cases including Polar Tankers, GM v. Tracey, CSX v. Alabama (I and II).
• Represented communication companies and utilities in a series of gross receipts tax lawsuits brought by Missouri local governments.
• Obtained dismissals and favorable settlements for various taxpayers in False Claims Act suits against relators and the Illinois Department of Revenue.
• Represented a Sprint affiliate regarding the application of the federal Internet Tax Freedom Act and the New York State sales tax to Sprint’s bundled services; approximately 80% of the taxpayer’s liability was ultimately abated.

• Served as lead trial and appellate counsel to several state cable associations and their members in a series of cases involving the application of the Commerce Clause to state tax laws designed to bring parity to the cable and satellite industries.
• Assisted several companies in preparing for and defending non-business income tax cases throughout the United States.
• Assisted several companies in preparing for and defending cost of performance income tax sourcing cases throughout the United States.
• Assisted several Fortune 500 companies in realigning and optimizing their state tax structures.
• Serves as national state and local tax counsel for several of the largest US cable, telecommunications and utility companies.
• Served as lead counsel for Duke Energy in income tax and sales tax cases against the South Carolina Department of Revenue and secured substantial tax refunds.
• Represents telecommunications companies in lawsuits brought by counties over Emergency 911 access charges.
• Represents a large telecommunications company in a California sales and use tax dispute.
• Represents a Fortune 100 telecommunications company in a corporate income tax dispute regarding cancelation of indebtedness income.
• Represents a large media company before the California FTB in a corporate income tax matter involving cost-of-performance sourcing.
• Won on summary judgment for a diversified financial corporation in Maryland litigation over a multimillion-dollar income tax assessment.
• Obtained the dismissal of a multimillion-dollar sales tax assessment in Tyson Foods v. Georgia.
• Represented a Fortune 50 media company in an Arkansas property tax matter related to central assessment and the assessment of intangible property.
• Served as counsel for See's Candies and obtained a landmark victory in a transfer pricing case against the Utah State Tax Commission.

• New York’s Beeline to Taxing Services, January 26, 2026, Eversheds Sutherland webcast
• State Tax – Significant Controversies Impacting the Communications Industry, May 14, 2025, TeleStrategies Communications Taxation Conference
• Emerging Issues in Administrative Deference, May 7, 2025, Spring 2025 STARTUP Conference State Tax Roundtable
• Transfer Pricing and Intercompany Transactions – Documentation, Documentation, Documentation!, April 29, 2025, COST Spring Meeting
• Challenging Assessments and Filing Protests, September 11, 2024, TEI Audits & Appeals Seminar
• State Tax Controversy – Update on Key Developments and Trends, June 13, 2024, TEI Region 8 Annual Conference
• Transfer Pricing and Intercompnay Transactions, December 5, 2023, TEI & IPT Silicon Valley SALT Seminar
• 2023 Litigation and Legislative Roundup, December 5, 2023, TEI & IPT Silicon Valley SALT Seminar
• State Tax Controversy Update - Update on Key Developments and Trends, June 15, 2023, TEI Region 8 Conference
• SALT Update, June 6, 2023, TEI Atlanta SALT Day
• Why State and Local Tax is Awesome!, June 6, 2023, TEI Atlanta SALT Day
• State Tax Litigation Update, May 4, 2023, 2023 Communications Taxation Conference
• An Update on Georgia’s Legislative Session and the SALT Landscape, April 13, 2023
• State Tax Controversy - Hottest Issues, June 9, 2022, TEI Region 8 Annual Conference
• State Tax Legislative and Litigation Update, May 4, 2022, Telestrategies Conference
• Transaction Tax Controversy, October 26, 2021, BTI Annual Conference
• State Tax Litigation Update, October 12, 2021, Telestrategies Conference
• Property Tax 101, May 20, 2021, Eversheds Sutherland 
• SALT Controversy, March 23, 2021, TEI Midyear Conference
• TEI’s 71st Midyear Conference, March 22-25, 2021
• TEI Richmond Chapter – SALT Session, March 18, 2021
• Audit Trends/Documentation for Audit Defense, March 18, 2021, TEI Richmond
• State and Local Tax Trends Communications Companies Should Know About, February 24, 2021, Telestrategies webinar
• Constitutional issues and special apportionment in the time of COVID, February 16, 2021, STARTUP Webcast and Meeting
• A cup of coffee with Duncan Riley, NYC Department of Finance, April 24, 2020
• COVID-19 property tax relief opportunities, April 20, 2020
• Communication Services Special Interest Group panel; "Legislative Updates, Industry Trends", October 28, 2019, Vertex Exchange 2019
• Regulatory/FCC Update, September 23, 2019, BTI Annual Conference
• State Tax Controversy Update, June 26, 2019, Region VIII Conference
• Conveying Your Litigation Message Effectively, May 22, 2019, 2019 Audit and Appeals Conference
• Taxing the Internet, the Next Frontier, May 14, 2019, Communications Taxation Conference
• State Tax Implications of the TCJA, April 1, 2019, 2019 TEI Mid-Year
• Wayfair – Interactive Panel Discussion on Its Implications and the States’ Reactions, February 27, 2019, COST 2019 Sales Tax Conference & Audit Session
• Discussion of State Tax Cases and Issues - Including the Post-Wayfair World, December 12, 2018, Council on State Taxation (COST)
• State Tax Controversy Update, June 6-10, 2018, Tax Executives Institute (TEI)
• State Tax Reform Roundtables, Summer 2018, Tax Executives Institute 
• Telestrategies' Communications Taxation Conference 2018, May 14-16, 2018, Telestrategies
• Audits & Appeals Seminar: State and Local Tax Controversy, May 2-3, 2018, Tax Executives Institute (TEI)

Books

• Chapter 21: The Sales Tax and Telecommunications, September 1, 2019, IPT’s Sales & Use Taxation, 3rd Edition

• Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax (2009-2010, 2013-2025)
• Recognized by The Legal 500 United States in the area of US taxes: contentious (2011, 2016-2025), US taxes non-contentious (2015-2016) and international tax (2018-2019)
• Recognized by The Legal 500 United States as a "Leading Lawyer" in the area of US taxes: contentious (2021-2024) and as a "Leading Partner" in the area of US taxes: contentious (2025)
• Recognized by The Daily Report (ALM) as a "Distinguished Leader" (2024)
• Recognized by Law360 as "Tax MVP of the Year" (2023)
• Recognized as a stand-out lawyer by Acritas Stars: Independently Rated Lawyers (2019-2020)
• Named to Best Lawyers in the areas of tax law and tax litigation and controversy (2021-2026)

• General Counsel, Georgia Cable Association
• Adjunct Professor, state and local taxation, Emory University School of Law
• Member, Georgia Governor’s Mentor-Protégé Program (assisting Georgia businesses in strategic development)
• Member, Advisory Board for Tax Law and Policy, Stafford Publications Inc.