Jane Dunlap CallahanShareholder
Ms. Callahan is a shareholder in the Orlando office. She represents taxpayers before the Internal Revenue Service to resolve tax issues at the audit and administrative appeals level, and represents taxpayers in the U.S. Tax Court and other federal courts. Ms. Callahan also represents a wide range of charities and other tax-exempt organizations, from their inception to handling tax and corporate issues.
Additional Representative Experience
Ms. Callahan and Dean Mead’s Tax Team represent clients before the Internal Revenue Service (IRS) during all phases of a tax examination (audit) or controversy, including preparing written protests and representing taxpayers at the IRS Appeals Office and litigation in the United States Tax Court, the Federal Court of Claims, the federal district courts, the federal circuit courts of appeals and the United States Supreme Court.
Ms. Callahan and her team handle issues relating to income tax, employment tax, estate and gift tax, and federal excise taxes. We represent individuals, corporations, partnerships and limited liability companies, and also tax-exempt organizations, regarding their tax issues. With extensive experience in both controversy procedures and tax law, we are able to develop resolution strategies that are individually designed and factually based on each client’s particular circumstances.
Ms. Callahan and Dean Mead’s Tax Team represent tax-exempt organizations with numerous organizational and operational issues. Ms. Callahan and her team assist clients in selecting the initial structure of the organization, such as Section 501(c)(3) charitable organizations, Section 501(c)(6) trade associations, Section 501(c)(4) social welfare organizations and a variety of other categories of tax-exempt organizations. She also assists in evaluating the tax-exempt purposes of the organization, qualifying it as tax-exempt and complying with laws governing tax-exempt organizations.
Many tax-exempt organizations wish to qualify under Section 501(c)(3) of the Internal Revenue Code because contributions to these organizations are deductible to the donors. Ms. Callahan assists clients in determining whether the organization qualifies as a Section 501(c)(3) organization. Each Section 501(c)(3) organization is further classified as a public charity or a private foundation and she helps our clients determine which status would be more beneficial to their organization.
In addition, Ms. Callahan handles tax issues that surround the qualification, operations and transactions of the tax-exempt organization.
Significant Representation – Section 501(c)(3) Tax-Exempt Organizations
Dean Mead represents public charities with a wide range of revenues and assets. Our larger public charity clients have assets in the range of $50 million to $90 million, and annual revenues of $35 million to $45 million. Our larger mid-size public charity clients have revenues in the $20 million range, and assets in the $3 to $5 million range. We also represent many start-up public charities.
Dean Mead represents private foundations in all phases of their lifespans, from the formation of new foundations to assisting with the operation of established private foundations. Our private foundation clients are formed by families or in connection with corporations. We represent private foundations with $12 million in assets, with assets in the $3 to $4 million range, and foundations with assets in the $1 million range. We evaluate private foundations as an option for charitable giving for families (both for current giving and future planning). We also assist corporate owners in evaluating the use of a private foundation and direct corporate giving (separately or in combination) in connection with their goals for corporate philanthropy.
Representative Experience (Private Foundations):
1) Formation and Qualification
Dean Mead assists its clients in determining whether to use a private foundation. When a client decides to use a private foundation, Dean Mead forms the private foundation, and assists the private foundation with compliance with state and federal laws. After consultation with the client regarding its proposed activities, the options for its legal structure and choices for corporate governance, Dean Mead prepares Articles of Incorporation and Bylaws, provides relevant corporate policies and prepared corporate resolutions, for the formation of the private foundation. Dean Mead prepares the application for recognition of exemption for filing with the Internal Revenue Service to establish the Section 501(c)(3) tax-exempt status of the organization. Dean Mead also assists with grant-making procedures, required distributions, investment policy procedures (impacted by federal and state law), and tax form filing requirements.
2) Private Foundation Requirements/Restrictions
Dean Mead advises its private foundation clients regarding the specific requirements and restrictions that are applicable to private foundations, and assists with corrective measures as necessary. Common issues for private foundations involve transactions between the private foundation and its founders, most of which are prohibited, and ownership of business enterprises. Compensation is also an important issue for many private foundations, and Dean Mead assists with compensation policies and compliance.
3) Advance Approvals Required for Certain Private Foundations Activities
Private Foundations are required to obtain advance approval for certain programs, such as scholarship programs. Dean Mead provides the guidelines for such programs and assists with obtaining the required approvals.
Professional and Civic Activities
- American Bar Association, Tax Section - Member
- The Florida Bar, Tax Section - Member
- The Florida Bar Foundation – Fellow
- Orange County Bar Association – Member
- The Rotary Club of College Park, Inc.
- Board of Directors, 2008 – 2011, 2014 - Present
- President, 2010 – 2011
- Member, 2007 - Present
- Girl Scouts of Citrus Council – Troop Leader
- Park Lake Presbyterian Church - Elder
- Christian Service Center
- Member of the Board of Directors, 2013 - Present
- Victory Cup Initiative
- Board of Directors
Charitable and Pro Bono Service
- Tax Clinic Project - Ms. Callahan joined the Earned Income Tax Credit Clinic Project and pro bono panel in 1995. The project helps working poor file their tax returns for free and focuses on assisting such wage earners to obtain the Earned Income Tax Credit. Over the past 20 years, she has volunteered for seven full evenings during each tax season.
- Master of Laws (LL.M.) in Taxation: University of Florida Levin College of Law, Gainesville, Florida, 1988
- Juris Doctorate Degree: University of Florida Levin College of Law, Gainesville, Florida cum laude, 1987
- Moot Court Board; The Order of Barristers
- Undergraduate Degree: Vanderbilt University, Nashville, Tennessee, 1984
- U.S. Court of Appeals 11th Circuit
- U.S. Court of Appeals 5th Circuit
- U.S. District Court Middle District of Florida
- U.S. Tax Court
Recognition & Awards
- Recognized for Outstanding Public Service by the Department of the Treasury, Internal Revenue Service Stakeholder Partnerships, Education and Communication, 2013, 2014 & 2015
- Honored with the Pro Bono Project Award of Excellence from the Orange County Bar Association Legal Aid Society, May 18, 2011
- Honored as the Best Lawyers® 2015 Orlando Tax Lawyer of the Year
- Named among The Best Lawyers in America, 2008-2018
- Named among the Orlando Magazine Best Lawyers, 2008-2017
- Martindale-Hubbell: Preeminent AV Rating
- Orlando to Host “Tax Reform” Seminar on Jan. 31: Sweeping Changes You Need to Know
- Donor Advised Funds Update (December 2017) – New Rules
- Join Us as We Take a Swing Against Hunger
- Dean Mead Supports 2017 Victory Cup Initiative
- Changes to the Florida Solicitation of Contributions Act
- Jane Callahan Speaks on Florida’s Charity Reform Law at the C/F/R Non-profit Series
- “Florida’s New LLC Act – What You Need to Know to Prepare” on Wednesday, Sept. 24
- Jane Callahan on Church Tax-Exempt Status in Orlando Sentinel
- Jane Callahan in GuideStar Blog on “Five Year-End Considerations for Nonprofits”
- Jane Callahan Authors Article on More Charitable Organizations Using Single-Member LLCs
- Swiss Government Allows its Banks to Release Account Holder Information to IRS
- Tax Season: What You Need to Know
- Jane Callahan to Speak at the “Trends in Philanthropy” Program on February 5th at the Orlando Museum of Art
- Charities’ Expanded Use of LLCs
- Florida Charities, Get Ready for UPMIFA!
- Estate Planning Seminar: 2011 Florida Legislative Update – Florida Uniform Prudent Management of Institutional Funds Act