Education
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New York University, LL.M., 1980
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Western New England School of Law, J.D., cum laude, 1979
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University of Connecticut, B.A., 1976
Bar Admissions
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District of Columbia
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Connecticut
Clerkships
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Hon. Meade Whitaker,
U.S. Tax Court,
1983
- 1985
Court Admissions
Awards and Honors
- Commendation from the President of the Republic of Armenia (for legal work performed), 2004
- Partner of the Year, Pro Bono Award (from previous firm), 2005
- Pro Bono Partner, Honorable Mention, 2006
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Susan Temkin counsels tax-exempt organizations—public charities, private foundations, social welfare groups, trade associations and political organizations, many with multi-national interests—on matters involving tax planning and policy. She represents clients before the Internal Revenue Service (IRS) and other offices of the Treasury Department, and advises on legislation and regulatory changes with the potential to impact the activities and interests of tax-exempt entities.
Ms. Temkin’s exceptional understanding of governance, compliance issues, reorganizations, investments and cross-border grant-making helps her clients develop strategies to operate with in the complex system of rules and regulations to minimize the risk of IRS investigations and enforcement actions, and resolve such controversies when they arise, promptly and efficiently. At local levels, she advises clients on steps necessary to achieve and maintain full compliance with state and local tax regulations.
Ms. Temkin has particular experience advising clients on private foundation excise taxes, distinctions between legislative activities and educational advocacy, limitations on legislative and political activities, the treatment and impact of unrelated business income, intermediate sanctions, subsidiary formation, disclosure requirements, anti-terrorist financing, private inurement and private benefit issues.
A vigorous advocate, Ms.Temkin has frequently protested adverse determinations or status denials. She has prepared comments for submission to Congress, the IRS, and Treasury regarding proposed legislation or regulations. She also has substantial experience advising for-profit corporations on corporate and investor transactions, corporate reorganizations, stock repurchase agreements, partnership agreements, debt and equity conversions, and other financial transactions.
Before joining Patton Boggs, Ms. Temkin counseled tax-exempt entities as a partner at one of the nation’s 25 largest firms, where she devoted substantial time and effort to pro bono work and was named Pro Bono Partner of the Year in 2005. After receiving her law degree, she joined the IRS office of Chief Counsel as an Attorney Advisor in the Interpretative Division and thereafter served as a Technical Advisor to the Associate Chief Counsel of the IRS. Since joining Patton Boggs, Ms. Temkin has continued her pro bono work, for which she was recognized with the firm’s Pro Bono Honorable Mention in 2006.
Representative Matters
- Represented a major network of affiliated exempt organizations on governance and tax issues raised by the Government Accountability Office.
- Advised the Bush Clinton Haiti Fund on foreign grant-making activities and issues.
- Structured a large publicly supported public charity established and coordinated through the joint efforts of current and former U.S. Ambassadors, a Foreign Minister, a former Chairman of the Joint Chiefs of Staff, the U.S. Department of State and the U.S. Department of Treasury to improve the social economic condition of people in a foreign country.
- Structured and restructured the governing documents and practices for numerous trade associations.
- Designed projects for the funding of overseas economic development programs, including a loan guarantee program for micro, small, medium and large size enterprises businesses for the Middle East and a loan program in Eastern Europe with the goals of creating positive economic and social change in low-income communities.
- Designed and structured infrastructure construction for schools, housing, road, and street construction; and cultural institution renovation and preservation in Eastern Europe for a major foundation.
- Counseled exempt organization regarding domestic and international grant making; drafted grant agreements and related documents, as well as private letter ruling requests for various international charitable products, including medical research.
- Obtained a ruling for a donor regarding an assignment of income issue for a significant gift exceeding $500 million.
- Orchestrated pre-submission conference and drafted a pre-submission filing for the reorganization of a stock exchange.
Professional Affiliations:
- American Bar Association, Taxation Section
- District of Columbia Bar Association, Taxation Section
- Emeritus Board of the Latino Student Fund
- Member of The University of Chicago Parent and Family Leadership Council, Fall 2008 to Present
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