Tax Controversy & Litigation

• Represent the Coca-Cola Company and subsidiaries before U.S. Tax Court contesting IRS transfer pricing adjustments of $9.4 billion related to the licensing of intangible property to foreign affiliates.  
• Represent ExxonMobil Corporation in a $1 billion income tax refund suit, related to handling of a deduction for federal fuel excise taxes involving a blend of ethanol and gasoline.
• Represent a Blue Cross and Blue Shield company before the U.S. Court of Federal Claims in a federal income tax refund suit valued at $185 million, involving a question of statutory interpretation under Section 833 of the Internal Revenue Code. The dispute poses an issue of first impression on which the IRS and taxpayers have disagreed for about a decade. 
• Represent a subsidiary of Valero Energy in an excise tax refund suit in the Western District of Texas under section 6426(e) for the Alternative Fuel Mixture Credit. The company is disputing a Revenue Ruling issued by the IRS that mixing butane and other alternative fuels with gasoline does not qualify for the credit. Assisted six other taxpayers with similar claims.
• Represent a major telecommunications company on a $225 million matter in connection with bonus depreciation rules following the Tax Cuts & Jobs Act of 2017 (TCJA).
• Prepared an audit defense plan for a large financial services company based on the client's anticipation that the IRS would inquire with respect to the substantive tax analysis and the application of various doctrines such as the economic substance doctrine. The audit defense plan included proactive submissions to the IRS audit team explaining the affirmative case in support of the tax reporting. The IRS team accepted the return position with no adjustments, providing support for the client's business groups to pursue similar investment opportunities. 
• Represent a company undergoing an extensive examination by the IRS to determine if the insurance program that it established and manages meets the tax law requirements for insurance, and whether penalties are appropriate. The program involves qualification of insurance companies under section 831(b), which has been the focus of IRS enforcement efforts in recent years.
• Represent an investment fund with several billion dollars of assets under management in connection with an IRS examination involving management fee waivers.
• Represent the trustee of a foreign trust in connection with an investigation by U.S. and foreign regulators related to purported tax evasion and money laundering. The matter involves the coordination of counsel and activities in multiple offshore jurisdictions and the U.S., litigation in several jurisdictions to obtain access to relevant documentation, and consideration of complex cross-border legal and privilege considerations.

Chambers USA

• Government Relations: Specialist Tax Firms (USA-Nationwide), 2019 - 2023
• Tax (District of Columbia), 2003 - 2023
• Tax: Controversy (USA-Nationwide), 2007 - 2023
• Tax: Corporate & Finance (USA-Nationwide), 2020 - 2023
• Tax Team of the Year, 2016

Legal 500

• Tax: Contentious (U.S.), 2007 - 2023
• Tax: International Tax (U.S.), 2013 - 2023
• Tax: Non-Contentious (U.S.), 2013 - 2023

International Tax Review

• World Tax (Washington, DC), 2012, 2014 - 2020, 2024
• World Transfer Pricing (National), 2014 - 2020, 2024
• "Americas Tax Awards": Americas Tax Policy Firm of the Year, 2012 - 2013, 2015 - 2016 
• "Americas Tax Awards": Washington, DC Tax Firm of the Year, 2013
• "Americas Tax Awards": Washington, DC Transfer Pricing Firm of the Year, 2012
• Tier 1 U.S. Firm, Tax Planning Survey, 2018

U.S. News - Best Lawyers® "Best Law Firms"

• Employee Benefits (ERISA) Law (District of Columbia), 2010 - 2024
• Employee Benefits (ERISA) Law (National), 2014 - 2024
• Litigation - Tax (District of Columbia), 2011 - 2024
• Litigation and Controversy - Tax (National), 2011 - 2024
• Tax Law (District of Columbia), 2010 - 2024
• Tax Law (National), 2010 - 2024