Cody J. Edwards
Suite 3700
Des Moines, IA 50309
Introduction
Cody practices in the area of taxation. Cody leads Dickinson Bradshaw’s state and local tax practice and is an experienced advisor to clients in the area of the federal Employee Retention Credit.
Mr. Edwards has been recognized by Best Lawyers® for his work in Litigation and Controversy—Tax Law (2024).
State and Local Tax
In the area of state and local taxation, Cody focuses on sales, use, and property tax controversy and litigation, multistate taxation, and general sales and use tax counseling. Cody has successfully represented before Departments of Revenue taxpayers of all sizes in industries including construction, manufacturing, health care, hospitality, technology, and agriculture. As a former attorney with the Iowa Department of Revenue, Cody brings unique insight to Iowa tax issues.
Employee Retention Credit
As a result of the aggressive and often misleading promotion of the Employee Retention Credit, along with repeated IRS warnings, clients have turned to Cody to provide an honest assessment of their eligibility of the Employee Retention Credit. Cody has helped numerous clients determine their eligibility for the ERC. Mr. Edwards has also helped third-parties with technical aspects of the law such as controlled group rules, full-time employee calculations, and the partial suspension test. Cody also provides second “opinions” on third-parties ERC analyses.
Mr. Edwards serves on the Board of the Iowa Taxpayers Association where he is an active member of the Sales and Use Tax Committee. Cody is a regular contributor to the Iowa Table SALT blog, Lexology, and is the editor of the Iowa Chapter of the American Bar Association’s Sales and Use Tax Deskbook.
Representative Matters:
Tax Controversy
- Successfully represented Illinois taxpayers in Iowa individual income tax audit regarding residency, ultimately reducing the Iowa Department of Revenue’s assessment by more than $2.5M.
- Successfully represented hospitality company in Iowa use tax audit, ultimately reducing Iowa Department of Revenue’s use tax assessment by $400,000.
- Successfully represented construction equipment dealers with respect in Iowa use tax audit, ultimately reducing clients’ assessments by more than $250,000.
Counseling
- Reviewed Iowa manufacturer’s sales and use tax processes resulting in identification of tax overpayments, tax saving opportunities and process gaps that created tax risks. Review resulted in tax refunds in excess of $400,000, millions of dollars in future savings, and recommendations for process improvements to reduce gaps
- Advised multi-state food manufacturer regarding the sales taxability of sales of prepackaged food products to private individuals and non- and for-profit health care entities located throughout the United States.
- Advised multistate technology company regarding its sales tax collection requirements as a result of the United States Supreme Court’s decision in South Dakota v. Wayfair, Inc.
- Advised numerous multistate manufacturers on their eligibility for employee retention credit.
- Advised numerous long-term care providers on their eligibility for employee retention credit.
- Advised numerous law firms on their eligibility for employee retention credit.
Practice Areas
Education & Background
Education
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J.D., University of Iowa College of Law
- B.A., University of Iowa
Prior Experience
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RSM US LLP, State and Local Taxation, Des Moines, Iowa, 2013-2016
- Iowa Department of Revenue, Attorney, Des Moines, Iowa, 2011-2013
Honors & Awards
Best Lawyers
- Selected for inclusion in the 2021-2023 edition of Best Lawyers: Ones to Watch in the areas of:
- Litigation and Controversy - Tax
- Tax Law
Jurisdictions
Admitted to practice in the following states:
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Iowa
Admitted to practice before the following federal courts:
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U.S. Tax Court
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U.S. District Court for the Southern District of Iowa
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U.S. District Court for the Northern District of Iowa
Memberships & Activities
- American Bar Association
- Member, Section of Taxation
- Iowa State Bar Association
- Member, Taxation Section
- Polk County Bar Association
- Iowa Taxpayer’s Association
- Member, Sales, Use, and Excise Tax Committee, 2015-present
- Member, Policy and Reform Committee, 2015-present
- United Way of Central Iowa
- Education Leadership Initiative, 2014–2017
- Capital Striders
- Member, Board of Directors, 2013-2017
- Chair, Scholarship Committee 2013-2017
- Backyard Boyz
- Advisory Committee, 2015-2017
- Ballet Des Moines
- Planning Committee, Black and White Ball, 2015-16
- Planning Committee, Runway Ballet, 2017
- Iowa Student Bar Association
- Student Representative, 2009-11
Articles, Presentations, and Publications
- Author, ERC Update: IRS says up to 90% of ERC Claims are High Risk or Show an Unacceptable Level of Risk, Iowa Tax Cafe Blog, July 9, 2024
- Co-Author, If Not Now, When? Is it Time to Consider a Refund Suit to Expedite ERC Processing by the IRS?, Iowa Tax Cafe Blog, February 21, 2024
- Co-Author, IRS Announces Withdrawal Process for Employee Retention Credit Claims, Iowa Tax Cafe Blog, October 19, 2023
- Co-Author, Latest IRS Guidance Demonstrates the Limited Basis for Claiming the ERC under a Supply Chain Disruption Theory, Iowa Tax Cafe Blog, July 25, 2023
- Co-Author, When the Taxman Cometh for (Potentially) Invalid ERC Claims, Iowa Tax Cafe Blog, July 19, 2023
- Co-Author, Red Flags to Consider when Using Third-Party ERC Advisors, Iowa Tax Cafe Blog, March 24, 2023
- Co-Author, Employee Retention Tax Credit: Potential Applicability for Law Firms, Iowa Tax Cafe Blog, March 23, 2023
- Co-Author, Clarifying Misconceptions Surrounding the Employee Retention Credit, Iowa Tax Cafe Blog, September 21, 2022
- Author, Iowa Department of Revenue Seeks to Narrow Sales Tax Exemption Through “Clarifying” Rulemaking, Iowa Tax Cafe Blog, July 20, 2021
- Author, Iowa Department of Revenue Issues Contradictory, Confusing Guidance Regarding Computer Sales Tax Exemption, Iowa Tax Cafe Blog, February 19, 2021
- Presenter, "Multistate Tax Considerations," Dickinson Law Startup Legal Webinar (available On Demand), October 8, 2020
- Author, IRS Issues Payroll Tax Deferral Guidance — Answering Some Questions, Iowa Tax Cafe Blog, September 3, 2020
- Author, Sales Tax Issues when Rebuilding After the Iowa Derecho, Iowa Tax Cafe Blog, August 14, 2020
- Author, 2020 Iowa Legislative Session Sales and Use Tax Changes, Iowa Tax Cafe Blog, July 13, 2020
- Co-Presenter (with Melissa Schilling & Bryan O'Neill), "Families First Response Act: Your Obligations as an Employer," Ankeny Chamber of Commerce Webiner, March 25, 2020
- Author, Festivus 2019: State Tax Edition, Iowa Tax Cafe Blog, December 20, 2019
- Author, Iowa Department of Revenue: Spinning Classes Subject to Sales Tax, but Not Pilates., Iowa Tax Cafe Blog, November 5, 2019
- Author, (Asset) Buyer Beware: Post-Acquisition Personal Liability for Seller’s Pre-Acquisition Sales Tax Liability, Iowa Table SALT Blog, May 20, 2019
- Author, Iowa’s Marketplace Facilitators: Auctioneers and Consignment Shops and Radio Stations, Oh My!, Iowa Tax Cafe Blog, February 20, 2019
- Author, Iowa Supreme Court Ruling Affects Construction Contractors’, Service Providers’ Sales Tax Obligations, Iowa Tax Cafe Blog, December 17, 2018
- Author, Congratulations, Apartment Owners, you May Be Required to Collect Iowa’s New Water Services Excise Tax, Iowa Table SALT Blog, October 31, 2018
- Author, LOST in an Iowa Use Tax Audit: Tax Return>Administrative Rules?, Iowa Tax Cafe Blog, Iowa Table Salt Blog, August 29, 2018
- Author, Iowa Sales Tax on Financial Institution Service Charges? Obviously?, Iowa Tax Cafe Blog, Iowa Table Salt Blog, August 24, 2018
- Author, U.S. Supreme Court Decision Opens Door for States to Tax Remote Sellers, Iowa Tax Cafe Blog, Iowa Table Salt Blog, June 21, 2018
- Presenter, Into the Abyss: Sales and Use Tax for Contractors, DMTH Webinar, June 19, 2018
- Author, Sales Tax Refunds Due After Iowa Narrows Manufacturing Exemption, Iowa Table Salt Blog, May 14, 2018
- Author, Let's Get Serious About Ending the Double Dip, Iowa Tax Cafe Blog, Iowa Table Salt Blog, March 26, 2018
- Author, Update: U.S. Supreme Court to Consider Internet Sales Tax Collection Law, Iowa Tax Cafe Blog, Iowa Table Salt Blog, January 15, 2018
- Co-Author (with Melissa Schilling), Employers: Be Cautious of the New Tax Law’s Incentive For Independent Contractors, Iowa Tax Cafe Blog, Iowa Employer Law Blog, January 9, 2018
- Co-Author (with David Repp), To C-corp or Not to C-corp? That is the Tax Question!, Iowa Tax Cafe Blog, Iowa Table Salt Blog, Start-Up Group Blog, January 8, 2018
- Author, Airing of Grievances--State Tax Edition, Iowa Tax Cafe Blog, Iowa Table Salt Blog, December 19, 2017
- Presenter, "Iowa Sales (and Use) Tax Issues: Practitioner's Perspective", Iowa State Bar Association, 2017 Bloethe Tax School, December 8, 2017
- Presenter, "Into the Abyss: Iowa Sales and Use Tax for Contractors", Associated Builders and Contractors, Iowa Chapter, November 14, 2017
- Author, What's in a Name? Iowa's "Computer" Sales Tax Exemption, Iowa Tax Cafe Blog, Iowa Table Salt Blog, December 5, 2017
- Author, Up in Smoke? New Iowa Law Regulating E-Cigarettes Raises Constitutional Issues, Iowa Tax Cafe Blog, September 6, 2017
- Author, Death and Taxes. Maybe., Iowa Tax Cafe Blog, June 20, 2017
- Author, The Greatest (Tax Policy) Evolution Story Ever Told, Iowa Tax Cafe Blog, June 6, 2017
- Author, IRC 2207A: Waiving Recovery of Estate Taxes Attributable to QTIP Trust, Iowa Trusts & Estates Blog, April 25, 2017
- Author, Lost in the Shuffle: Federal Tax Reform’s Impact on Iowa Tax Revenue, Iowa Tax Cafe Blog, April 19, 2017
- Author, The Times They Are A-Changin': States Challenge Long-Standing Sales Tax Nexus Standards, Iowa Tax Cafe Blog, March 13, 2017
- Author, Seinfeld and the Iowa Department of Revenue, Iowa Tax Cafe Blog, March 3, 2017
- Author, A Primer on Private Foundations, Iowa Tax Cafe Blog, March 1, 2017
- Author, More Money on the Table, Iowa Tax Cafe Blog, February 21, 2017
- Author, Money on the Table: Iowa Economic Incentives, Iowa Tax Cafe Blog, February 20, 2017
- Author, IDOR Rules That Internet Streaming is Subject to Sales/Use Tax - Is It Really? Iowa Tax Cafe Blog, February 13, 2017
- Author, Back to Basics: Iowa Use Tax, Iowa Tax Cafe Blog, February 7, 2017
- Co-presenter (with Brad Hershberger), “Hot Topics in Iowa’s Sales and Use Tax,” Associated General Contractors of Iowa Controllers Council and CFMA Joint Meeting, Ames, Iowa, April 21, 2016.