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Bradley Arant Boult Cummings LLP

Bruce P. Ely

Bruce P. Ely



  • Economic Development
  • Governmental Affairs
  • Energy

WSG Practice Industries



Bruce Ely’s more than 35 years of experience have allowed him to handle projects as diverse as serving on the recruiting teams that successfully induced both Mercedes-Benz and Hyundai to locate their first U.S. manufacturing plants in Alabama to representing taxpayers before the Internal Revenue Service, the Alabama Department of Revenue and local taxing authorities. His practice focuses on three concentric areas: representing taxpayers in federal, state and local administrative and judicial forums; advising companies on choosing the proper form of entity through which to conduct business in the southeast and potential tax incentives; and advising companies and various trade and professional organizations regarding state and local tax legislative matters. He also devotes a substantial amount of time to teaching and writing on SALT-related topics.

Bruce was founding chair of the firm’s State and Local Tax (SALT) Practice Team, which represents taxpayers before the Alabama, Tennessee and Mississippi Departments of Revenue, as well as local government taxing authorities and the state and federal courts. He has served as counsel to multistate taxpayers in cases before the U.S. Supreme Court, but more often before the Alabama appellate courts, circuit courts, and the Alabama Tax Tribunal. He also recently co-chaired the New York University Institute on State & Local Taxation and was selected by State Tax Notes/Tax Analysts as one of its “Top Ten Tax Lawyers in the U.S.”

As part of his governmental affairs practice, Bruce has co-authored a number of landmark pieces of tax and business entity legislation in Alabama and numerous statute-specific tax bills. He was privileged to serve as counsel to several state tax reform, economic development and constitutional reform commissions over the years and has written extensively on those topics, as well as on other multistate tax issues and incentives matters. He also speaks regularly on the tax aspects of pass-through entities at the national and state levels, and co-authors a series of charts on the state taxation of LLCs and LLPs that have appeared in numerous tax and business entity journals and treatises.

Bruce also serves as co-lead editor of Bloomberg BNA’s Pass-Through Entity Navigator, a comprehensive online resource providing detailed analysis and practical guidance on a state-by-state basis for each type of pass-through entity and pass-through entity owner. The resource tool allows tax professionals to quickly access more than 1,700 topics, such as formation, federal tax classifications, taxes imposed, withholding, or composite returns, and is available to subscribers of Bloomberg BNA’s Tax & Accounting State Tax research.

As a longstanding Fellow of the American College of Tax Counsel, Bruce is the only Alabama member included in the International Who’s Who of Corporate Tax Lawyers.

Bar Admissions

  • Alabama, 1980

Court Admissions
  • Supreme Court of the United States
  • United States Court of Appeals, 11th Circuit
  • Supreme Court of Alabama
  • United States Tax Court
  • United States District Court, Northern District of Alabama


  • New York University School of Law, LL.M. (Taxation), 1981
  • University of Alabama School of Law, J.D., 1980, with honors; Moot Court Board; Bench and Bar
  • University of Alabama, B.S., Accounting, 1977, cum laude; Beta Gamma Sigma and Beta Alpha Psi Honorary Academic Fraternities, 1976
Areas of Practice

Economic Development | Energy | Governmental Affairs | Retail | State and Local Tax | Tax | Tax Controversy and Litigation


An Update on the State Tax Treatment of LLCs and LLPs
Bradley Arant Boult Cummings LLP, February 2021

The owners of multistate businesses must consider many factors when deciding how to structure their business ventures, and state taxation should not be overlooked. The accompanying tables can assist in that evaluation for limited liability companies and limited liability partnerships. In recent years, LLCs and, to a lesser extent, limited partnerships and LLPs have become the popular choice for structuring or restructuring multistate business entities...

COVID-19 Payroll Tax Notice from the IRS Offers Sparse Guidance
Bradley Arant Boult Cummings LLP, August 2020

Following the August 8, 2020 Presidential Memorandum directing the Treasury Secretary to defer the withholding, deposit, and payment of certain payroll taxes, the Internal Revenue Service released Notice 2020-65 late Friday, August 28. The brief notice gives necessary but sparse guidance on implementing the Presidential Memorandum. We expect (and hope for) further guidance soon...


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