Allison Rule

Partner

About

Ms. Rule is a partner and heads the firm’s Communications Taxes and Fee Practice. Ms. Rule also counsels clients in a variety of transactional, land use, regulatory, litigation and dispute resolution matters.

Ms. Rule regularly assists clients in all phases of transaction tax planning, including audit preparation and defense, corporate compliance monitoring, developing and implementing tax planning strategies. Ms. Rule has gained substantial expertise in the taxation and regulatory treatment of evolving and advanced communications services, including cloud-based services, IP-enabled services, and software services. Ms. Rule has assisted numerous VoIP and cloud-based providers in understanding the complexities of state taxation of communications and advanced services.

In her transactional and regulatory practice, Ms. Rule assists clients with drafting and negotiation of a wide variety of commercial contracts and license agreements with upstream providers, resellers, and end-users. Ms. Rule advises clients on regulatory compliance matters and guides clients through the myriad of state and federal regulatory obligations faced by providers of advanced services. In particular, Ms. Rule assists both recipients of and participants in the FCC’s universal service programs in order to ensure compliance with complex requirements while maximizing revenue protection opportunities.

Ms. Rule also counsels clients on corporate mergers, acquisitions, and other corporate restructuring matters. Specifically, Ms. Rule performs regulatory and tax due diligence services for both buyers and sellers in corporate acquisitions. Ms. Rule also works with corporate clients in undertaking corporate monitoring and internal compliance audits.

Ms. Rule’s clients have included VoIP providers, providers of cloud-based communications services, satellite service providers, electric utilities, gift card providers, mobile payment providers, tribal organizations, software developers and providers, domestic and international long distance providers (IXCs), wireless and MVNO providers, Competitive Local Exchange Carriers (CLECS), prepaid communications providers, municipal and commercial providers of communications services, consumer advocacy groups, and communications equipment manufacturers.

About

Ms. Rule is a partner and heads the firm’s Communications Taxes and Fee Practice. Ms. Rule also counsels clients in a variety of transactional, land use, regulatory, litigation and dispute resolution matters.

Ms. Rule regularly assists clients in all phases of transaction tax planning, including audit preparation and defense, corporate compliance monitoring, developing and implementing tax planning strategies. Ms. Rule has gained substantial expertise in the taxation and regulatory treatment of evolving and advanced communications services, including cloud-based services, IP-enabled services, and software services. Ms. Rule has assisted numerous VoIP and cloud-based providers in understanding the complexities of state taxation of communications and advanced services.

In her transactional and regulatory practice, Ms. Rule assists clients with drafting and negotiation of a wide variety of commercial contracts and license agreements with upstream providers, resellers, and end-users. Ms. Rule advises clients on regulatory compliance matters and guides clients through the myriad of state and federal regulatory obligations faced by providers of advanced services. In particular, Ms. Rule assists both recipients of and participants in the FCC’s universal service programs in order to ensure compliance with complex requirements while maximizing revenue protection opportunities.

Ms. Rule also counsels clients on corporate mergers, acquisitions, and other corporate restructuring matters. Specifically, Ms. Rule performs regulatory and tax due diligence services for both buyers and sellers in corporate acquisitions. Ms. Rule also works with corporate clients in undertaking corporate monitoring and internal compliance audits.

Ms. Rule’s clients have included VoIP providers, providers of cloud-based communications services, satellite service providers, electric utilities, gift card providers, mobile payment providers, tribal organizations, software developers and providers, domestic and international long distance providers (IXCs), wireless and MVNO providers, Competitive Local Exchange Carriers (CLECS), prepaid communications providers, municipal and commercial providers of communications services, consumer advocacy groups, and communications equipment manufacturers.

Representative Experience

  • Performing regulatory audits examining the appropriate classification of IP-enabled and cloud-based services and advising as to the related regulatory obligations imposed on providers of such services
  • Assisting clients with transaction tax and regulatory fee compliance and planning
  • Advising clients regarding tax and regulatory implications associated with new and developing products and services
  • Advocating on behalf of clients in federal and state rulemaking and adjudicatory proceedings
  • Preparing privacy policies, end user agreements, terms of use, and customer service agreements
  • Participating in and assisting corporate clients with internal corporate audits and monitoring
  • Assisting communications providers in gaining access to necessary infrastructure, such as rights-of-way, utility poles and conduits, commercial buildings, and wireless structures agencies
  • Advising clients on matters involving OFAC compliance and anti-fraud programs (KYC and CIP)

Publications and awards

  • Cloud Computing – Taxing the Cloud, TechNet Magazine (2013)
  • Contributor, Law360
  • Washington and Lee School of Law:Women in the Law: Finding the Work/Life Balance (2006)
  • SmartCEO Award, Outstanding Attorney (2015)
  • American Foundation for the Blind– Annual Access Award

Education

Graduate with honors from Texas A&M University, and she earned her Juris Doctorate from Washington & Lee University School of Law in 1999.

Admissions

Ms. Rule is admitted to practice in the State of Maryland and the District of Columbia and is a member of the bar of the United States Courts of Appeals for the Fourth Circuit and the United States Federal Circuit.

Practices

  • Communications Tax and Fee Compliance and Planning
  • State and Local Transaction Tax Compliance and Planning
  • Transaction Tax Audit Preparation and Defense
  • Telecommunications, VoIP and Cloud Communication Services
  • USAC Compliance, Audit Preparation and Defense / PaaS / XaaS)
  • Corporate Due Diligence and Compliance Monitoring
  • FCC Advocacy
  • Corporate Acquisitions and Restructuring
  • Product Development and Tax Mapping
  • Wireless Communications and MVNOs
  • Communications Infrastructure and Access
  • International Telecommunications
  • Dispute Resolution and Litigation
  • Money Transfer/Financial Services
  • Internet of Things & Connected Devices

Speaking Engagements

  • Speaker at TeleStrategies 2015, “Ask a Lawyer Panel”
  • Speaker at TeleStrategies 2014, Confronting Regulatory Classification Uncertainties and Mitigating Risk Through the Tax Mapping Process”
  • Speaker at TeleStrategies 2013, “Regulatory and Tax Issues Impacting Non-Interconnected VOIP and Other ‘One-way’ VOIP Services”
  • Speaker at Prepaid Press Expo 2012, “Navigating Through Prepaid Regulation & Legislation: Payments Regulations”
  • Speaker at TeleStrategies 2012, “Advanced FCC Revenue Reporting: Misperceptions, Mistakes & Missed Opportunities”