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Brian C. Stegeman
Associate

(612) 252-2861

Practice Areas

• Tax Law
• Sports and Entertainment Law

Practice Summary

Brian’s practice is split between two areas: Entertainment and Tax. 

Although he is a life-long musician who co-founded a successful music business before entering the legal profession, Brian’s entertainment practice focuses primarily on legal representation, management and marketing of athletes, particularly professional mixed martial arts (“MMA”) fighters (or “Ultimate Fighters”).  Brian provides a full range of services to athletes, including negotiation and execution of promotional, endorsement and licensing agreements, public relations, protection of intellectual property, general business formation and transactions, as well as tax and estate planning.

On the tax side, Brian holds an LL.M. in Taxation from New York University, and regularly represents clients before the Internal Revenue Service and state taxing authorities.   A significant portion of his tax practice is dedicated to resolving federal, state and local tax controversies.  Additionally, he handles tax-related issues in the areas of employee benefits, estate planning and administration, and mergers and acquisitions. 

Representative Clients

Entertainment/Sports

• UFC Heavyweight Champion, Brock Lesnar
• DeathClutch Clothing and Apparel 
• UFC Fighter, Chris “The Crowbar” Tuchscherer

Tax

• Anoka Independent Grain and Feed Dealers
• Fair Isaac Corporation

Representative Experience

Entertainment

• Negotiated promotional agreements with virtually every major international  MMA organization, including Ultimate Fighting Championship (UFC),  Fighting and Entertainment Group, Inc. (FEG, Inc., promoter of K-1 World GP Series, K-1 World Max Series, and Dream), World Victory Road/Sengoku, and Bellator Fighting Championships.
• Negotiated endorsement/sponsorship agreements with major corporate sponsors, including Jack Link’s Beef Jerky, Jimmy John’s, Dymatize Nutrition, ATK/Federal Premium Ammunition, and Polaris.
• Negotiated licensing and merchandising agreements.
• Coordinated major national media appearances, including, for example, ESPN, Muscle & Fitness, and GQ magazine, and handled ongoing public relations for clients.
• Registered and enforced copyrights and trademarks.

Tax

Generally:

• Successfully represented clients in Federal and State income, sales, and estate and gift tax audits and administrative appeals.
• Secured re-examinations of previous audits and assessments, and protected clients from liens, levies, asset seizures, penalty assessments, and Trust Fund Recovery Penalty assessments.
• Negotiated installment agreements and offers in compromise with the IRS and the Minnesota Department of Revenue.
• Obtained tax-exempt status for non-profit corporations and provided ongoing counsel to ensure such corporations maintain tax-exempt status.

Specifically:

• Represented multinational corporation in connection with successful settlement of federal administrative appeal involving research and development credit and the extraterritorial income exclusion.
• Prepared federal and state estate tax returns and represented estate in connection with federal and state estate tax audits involving complex multi-million dollar family farm business that resulted only in insubstantial audit adjustment.
• Represented Chief Financial Officer of corporation in Minnesota Tax Court case involving DOR assertion of CFO's personal liability for Minnesota sales tax liability of corporation ultimately resulting in no liability for CFO.
• Represented small technology business in connection with reconsideration of DOR sales tax audit and appeal resulting in significant adjustment in favor of taxpayer and acceptance by DOR of installment agreement.
• Amended nonqualified deferred compensation plan to ensure Internal Revenue Code Section 409A compliance.
• Prepared and received favorable IRS private letter ruling.

Professional / Academic Honors

• Recognized as a Rising Star (top 2.5 percent of lawyers in the state practicing less than 10 years) by Super Lawyers magazine in the tax/entertainment areas in 2008, 2009 and 2010
• Received L. Charles and Lillian Gay Endowment Merit Scholarship.
• Legal Writing Honors
• Dean's list (with an "A" average), 2001-2002

Publications / Speaking Engagements

• Featured in Minnesota Law & Politics, “The Fighters Behind the Ultimate Fighter” 
• Co-Presented, 2009 Henson & Efron Seminar Series, “Doing Business on the Internet.”
• Co-Presented, Tax Training Session on IRC 409A.
• Co-authored and co-presented, 2007 Henson & Efron Seminar Series, “Advanced Choice of Entity: Tax and Non-Tax Considerations”
• Co-authored and Presented, Hennepin County Bar Association’s CLE course, "2007 Federal and State Tax Law Updates," April 2007; discussed IRC Section 338(h)(10) elections and the Nadler v. Commissioner decision
• Co-authored and co-presented 2006 Henson & Efron Seminar Series, “Estate Planning 101: Your Clients Can’t Take ‘It’ With Them – How They Can Leave ‘It’ Behind”

Education

• Master of Laws (LL.M.) in Taxation, New York University School of Law
• Juris Doctor, cum laude, University of Minnesota Law School
• Bachelor of Arts, Philosophy, University of Minnesota

Bar Admissions

• Minnesota

Professional Memberships

• American Bar Association
• Minnesota State Bar Association
• Hennepin County Bar Association

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