Michael J. Semes

Of Counsel

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Mike utilizes over 30 years of government executive, financial and academic experience to drive state and local tax value to his clients in their most significant controversies and transactions. Mike has served as Pennsylvania Governor Tom Ridge’s Chief Tax Counsel, has been a partner in two ‘Big 4’ firms and is currently a professor of practice at Villanova University Law School Graduate Tax Program. This diverse background enables collaboration with his clients to examine various issues through legal, regulatory, policy, procedural, financial, reputational and academic lenses, leading to practical, goal-oriented solutions.

Mike has handled a broad range of tax issues and won significant victories in many state forums. From a sector perspective, he has a wealth of experience working with companies on both the regulated and non-regulated sides of the energy industry. Mike has also been actively involved in following, writing and speaking about the recent trends in adopting and proposing digital advertising taxes.

Select Experience

  • Served as Chief Counsel of the Pennsylvania Department of Revenue under Governor Tom Ridge.
  • Drafted significant tax legislation and regulations.
  • Assists Fortune 500 clients in resolving significant state and local tax issues.
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  • Served as Chief Counsel of the Pennsylvania Department of Revenue under Governor Tom Ridge.
  • Drafted significant tax legislation and regulations.
  • Assists Fortune 500 clients in resolving significant state and local tax issues.
  • Negotiated hundreds of settlements and letter rulings in multiple states and argued numerous cases before administrative and judicial bodies.
  • Led a team of attorneys and professionals that delivered tax solutions to some of the world’s largest power producers, regulated energy delivery companies and water utilities.
  • Reported tax decisions in MI, PA, and NJ with outcomes that were favorable to the clients.
  • Represented Pennsylvania utility in Public Utility Realty Tax Act dispute regarding the definition of “cost” in which the Pennsylvania Supreme Court awarded the taxpayer a $55.7 million refund.
  • Represented Pennsylvania bank in matter involving the calculation of the surviving bank’s Bank Shares Tax base following its acquisition of another bank. The Commonwealth Court held in favor of the bank that the statute violated the Uniformity Clause.
  • Represented privately held oil and gas company at the Michigan Tax Tribunal in challenging the Department’s assessment of Michigan Business Tax (MBT). The Tribunal ruled that the client was permitted to deduct its depletion allowance from its MBT income, which eliminated the Department’s assessment and granted client a refund.
  • Represented out-of-state software licensor in a dispute over whether the licensor was subject to New Jersey Corporate Business Tax (CBT). The New Jersey Tax Court held that because New Jersey sales tax law defined canned software to be tangible personal property that Public Law 86-272 (15 U.S.C. § 381) precluded the Division of Taxation from subjecting the licensor to CBT.

Recognitions and Memberships


  • Registered Lobbyist, Pennsylvania


  • Philadelphia Bar Association
    • State and Local Tax Subcommittee: Chair
  • WorldTrade Executive: Former Board Member
  • Former Pennsylvania Governor Ed Rendell, Tax Transition Team
  • Former Philadelphia Mayor Michael Nutter, Tax Advisory Council




  • Settlement Music School: Board Member (2016 to Present)
  • Astral Artists: Board Member (2014 to 2016)

Prior Positions

  • Villanova University Charles Widger School of Law and Graduate Tax Program: Professor of Practice (Present)
  • Ernst & Young, National Tax Department: Principal
  • PricewaterhouseCoopers: Partner
  • Pennsylvania Department of Revenue: Chief Counsel


  • Pennsylvania
  • Delaware


  • J.D., Villanova University School of Law, 1990
  • M.F.A., Carnegie Mellon University, 1981
  • B.M., Duquesne University, 1979, summa cum laude


In The Blogs

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Employment Law Spotlight
Will states ‘come together' to resolve remote work tax withholding issues … or will we continue ‘waiting here … on the long and winding road?'
By Michael J. Semes, Amy J. Traub
March 14, 2022
As we previously reported, the National Labor Relations Board (the Board) invited public comment in January on whether it should overrule its current standard for determining the lawfulness of employee handbook policies and work rules...
Employment Law Spotlight
Tax Withholding Policies in a Work-From-Home Environment
By Edward J. Bernert, David D. Ebersole, Matt Hunsaker, Michael J. Semes, Christopher J. Swift
December 7, 2021
Working from home some or all of the time has become commonplace and seems likely to continue regardless of what happens with the COVID-19 pandemic. New ways of working require new ways of handling tax withholding. Employers may need to...