The Legal 500

Mayer Brown’s combined tax controversy and transfer pricing practice has achieved national penetration. Commended for a partner-led approach, the 40-lawyer group ‘gives outstanding service; the promptness is unparalleled and the diverse talent provides a wide array of knowledge and experience’. It is one of the few firms with the capacity to litigate several complex tax controversy cases simultaneously. Chicago houses the largest team, with smaller but equally expert groups in New York, Palo Alto and Washington DC. Effective team building and excellent inter-office communications overcome geographic distance. Much of the tax practice work is self-generated, although the impressive support is also provided to other departments. The ‘outstanding’ Joel Williamson in Chicago and Larry Langdon in Palo Alto co-chair the practice. In a high-profile instruction, Chicago’s Thomas Kittle-Kamp, who ‘provides practical advice as well as in depth technical analysis’, and Washington DC-based David Abbott and Nicole Reuling, ‘an accomplished courtroom performer’ recently promoted to equity partner, are representing Union Bank of California in a case involving leveraged leases of hydroelectric power facilities and sports entertainment complexes. The same trio, were joined by Williamson and two other Chicago residents, Thomas Durham and William Schmalzl, to conclude a major victory for Consolidated Edison Company of New York before the US Court of Federal Claims: the $400m case involved the taxation of a complex leveraged lease transaction. Other recommended lawyers in Chicago include Patricia Anne Rexford, for transfer pricing and tax credit matters, and Scott Stewart for a wide range, including economic substance and competent authority disputes. In Washington DC, Charles Triplett, is probably the most knowledgeable lawyer in the US on advance pricing agreements and competent authority negotiations. Clients include Exelon, Flextronics, Guidant Corporation, JPMorgan and Wells Fargo Bank.

Skadden, Arps, Slate, Meagher & Flom LLP’s tax controversy group has a well-balanced spread of age and experience. Typical instructions include complex tax audits, stock option back-dating, high-value IRS disputes, promoter penalty fast-track proceedings, tax fraud investigations, and formal and informal IRS rulings. The Washington DC-centered tax group has ‘the best assembly of former government people in the market’, co-head Fred Goldberg, and Kenneth Gideon served in senior government positions in tax policy and administration, and members of the team have represented clients in every level of court. In recent instructions, Albert Turkus has been involved in two major trials before the US Tax Court on behalf of clients Hewlett-Packard and Axcess Financial, and B John Williams, who served as chief counsel to the IRS, has been representing a company in an administrative appeal pending before the IRS concerning a proposed disallowance of interest accrued on intercompany financing amounting to $302m each of the fiscal years 2003, 2004 and 2005; the matter is now expected to litigate. Alan Swirski acted for Entergy in the US Tax Court in a nuclear industry issue concerning plant decommissioning liability. Julia Kazaks has built a strong reputation in employee/contractor classification, and the economic substance and business purpose doctrines; she regularly represents clients in the pharmaceutical, energy and transportation sectors. Pamela Olson has a reputation for understanding the business issues underlying tax disputes, and includes master partnerships, life assurance and not-for-profit expertise in her broad practice portfolio. Susan Seabrook, recommended for all insurance and reinsurance controversy, joined the Washington DC as of counsel from Latham & Watkins LLP in the fall of 2010. The team also handles complex tax fraud and professional standards instructions. The group’s recent clients include the American Council of Life Insurers, Wells Fargo and Bank of New York Mellon.

Baker & McKenzie has handled thousands of administrative tax controversies and docketed hundreds of cases in court. The practice provides ‘the most timely and necessary expertise as needed, and identifies how to maximize tax opportunities on existing business initiatives’. The firm’s market-leading international transfer pricing practice has national penetration through effective inter-office co-operation and utilizing the services of economists as well as lawyers. Group chair Thomas Linguanti, in Chicago, ‘focuses on bringing the appropriate talent to bear, and where necessary, makes the necessary investment of time required to strengthen an already strong and long term business relationship’. The firm has expertise in virtually every industry, and ranks as one of the few international law practices which competes with the top-four accountants in transfer pricing. In significant transfer pricing litigation, Mark Oates from the Chicago office, and Andrew Crousore from Palo Alto, led the work for Symantec Corporation in the first case to consider an arm’s length buy-in value under Section 482 of the IRS Tax Code; the Tax Court held that the method proposed by the IRS was arbitrary, capricious and unreasonable. Other lawyers recommended include ‘very solid and reliable’ Gregg Lemein in Chicago. Washington DC’s Duane Webber and Thomas Linguanti serve as Boeing’s main outside tax counsel, advising Boeing on worldwide tax matters, including tax controversy. Major clients include Electronic Arts, Medtronic, PepsiCo and Thomson Reuters.

Dewey & LeBoeuf LLP’s New York-based ‘pre-eminent specialist in tax controversy, procedure and administration’ Lawrence Hill heads the 53-fee-earner tax controversy practice, which provides ‘excellent service and sound judgment’. The group has established a strong following of financial institutions and insurers whose instructions include cross-border issues, as well as US federal tax matters, and is also active in white-collar criminal defense. Insurance taxation guru George Abramowitz is handling crucial litigation on behalf of second-biggest bond insurer Ambac Assurance; the IRS is disputing the effect of a restructuring intended to ring fence liabilities and is demanding payment of an incorrectly claimed tax refund of $700m, a sum in excess of available cash sufficient to trigger a process which would require the closing of open swap positions to a value of $3bn. In Washington DC, Abraham ‘Hap’ Shashy, a former chief counsel of the IRS, bridges controversy and complex transaction planning, and Tamara Ashford is an experienced appellate litigator with considerable expertise in complex offshore and international matters. In New York, Seth Farber combines tax controversy with antitrust litigation, and Mark Allison has represented several international banks in IRS examinations and appeals. Practice clients include AIG, Barclays, Citigroup, Deutsche Bank, G-I Holdings, Mirant Corporation and HSBC.

Latham & Watkins LLP’s main complement of tax controversy lawyers is based in Washington DC, where the highly rated Gerald Kafka heads the group, which offers excellent depth in the associate ranks, as well as expert partners. Rita Cavanagh, who has established a niche in the representation of tax professionals undergoing investigation by the IRS Office of Professional Responsibility (OPR), and Julian Kim, recommended for complex controversies, are among group members with experience in the IRS or Department of Treasury. Also in Washington DC, Kim Marie Boylan is expert in the tax aspects of accounting, and has a particular interest in the digital media sector. In Chicago, the ‘experienced, knowledgeable and friendly’ Roger Jones represented Vi, formerly known as ‘Classic Residence by Hyatt’, in connection with proposed income adjustments over $400m; the point at issue was whether refundable entrance fees should be included in income in the year of receipt as prepaid rent. A heavyweight team including Roger Jones and former tax department head Stephen Bowen succeeded for the Kroger Company in two cases before the US Tax Court to overturn the IRS disallowance of some $800m depreciation and amortization deductions. Noteworthy expertise on offer includes insurance sector taxation, although the practice is capable of handling all types of dispute, including transfer pricing, with expertise and efficiency. Clients include Wilmington Partners, Magma Power, CIGNA Corporation, and Bausch & Lomb.

McDermott Will & Emery LLP is ‘without doubt one of the best firms I have dealt with in 35 years of practice; very responsive, highly competent, tenacious and achieves terrific results’. Washington DC-based Jean Pawlow, ‘detail-oriented and an excellent high energy advocate’, heads the tax controversy practice, which is widely recommended for IRS audits and appeals of the greatest complexity, competent authority negotiation, and trial and appellate litigation. The group fields 15 partners and is lightly leveraged with 15 associates, with the largest concentrations in Chicago and Washington DC, and more modest representation nationwide. The firm’s origins as a tax firm persist and the majority of instructions to the controversy group originate outside the firm. Acclaimed attorneys for federal tax matters include Thomas Borders, who is ‘an outstanding advisor on litigation strategies with a strong courtroom presence’; Borders masterminded the successful defense of law firm Bryan Cave in a number of state and federal court tax malpractice actions brought by individual plaintiffs as well as two class actions in federal court. Also in Washington DC, George Benson, ‘exhibits phenomenal perception and insight on a broad mix of tax issues’, and has developed a niche in the representation of cooperatives involved in federal income tax controversies. In New York, Thomas Giegerich provides ‘comprehensive tax expertise’. Other lawyers recommended for federal tax controversy include, in Washington DC, Martha Groves Pugh, who is expert in energy industry issues, and William Goldman, highly experienced in appellate litigation. Robin Greenhouse is expert in administrative matters and tax practitioner privilege. In Chicago, Gregory Palmer brings international tax expertise to his controversy practice. New York is also home to a noteworthy state tax group with a nationwide reputation, headed byArthur Rosen, who has 'a very broad state knowledge base, and is able to put concise direct answers together – which reads as not having high billable hours’. Peter Faber is also highly rated for SALT instructions. Leah Robinson is working with New York-based Peter Faber to represent Pfizer in ongoing litigation as to whether New Jersey’s method of allocating the income of a multi-state corporation is constitutional. Chicago’s Jane Wells May, head of the firm's SALT practice, who is ‘energetic and provides rapid response’, has been retained to develop a national strategy for defending all state controversies by a leading domestic retailer. Practice clients include Chevron, Citibank, Honeywell, HSBC and John Hancock.

Bingham McCutchen LLP’s William Nelson in Washington DC, and Donald-Bruce Abrams in Boston, co-chair the firm’s tax group, in which about half of the 50-strong team focus on controversy. The controversy lawyers attract numerous high-value and complex instructions from such major corporate clients as Dow Chemical, HIT Entertainment, GlaxoSmithKline and Pernod Ricard. Key litigators include Michael Desmond, David Curtin, and Raj Madan, who is a member of the team representing Sovereign Bancorp is one of the current leading cases involving what the IRS has termed “foreign tax credit generators”. John Magee leads the transfer pricing section, to which Sanford Stark, highly recommended for federal tax instructions, also contributes. Craig Sharon, former director of the Advance Pricing Agreement Program at the IRS, joined the firm’s Washington DC office in January 2011. Attorneys are based in Washington DC except where indicated otherwise.

Caplin & Drysdale’s Washington DC-based tax controversy group comprises some ten partners practicing fully in the field, and four tax partners with a flexible part-time interest in the practice. The group is lightly leveraged, and clients comment positively on the partner-level commitment on offer. The firm ranks very high on the shortlist of firms recommended for voluntary disclosure and criminal tax fraud instructions. Recent ongoing work includes some 400 cases under the 2009 IRS Voluntary Disclosure Process, and the firm is well placed for anticipated further disclosure programs: recommended in this space are Scott Michel, Cono Namorato and Nile Elber. Christopher Rizek and Charles Ruchelman have recently handled several major tax shelter disputes on behalf of financial institutions. Richard Skillman has expertise in insurance, and is recommended for non-criminal tax controversy and litigation.

Chamberlain, Hrdlicka, White, Williams & Martin’s George Connelly in Houston, heads the tax controversy group which comprises some 25 attorneys in Texas and Philadelphia. The group provides ‘strategic and tactically savvy advice and relative value’. In Houston, Larry Campagna ranks as the practice heavyweight in white-collar crime and tax fraud, and David Aughtry in Atlanta is an inventive and persuasive litigator who has appeared in the Supreme Court. In Philadelphia, Philip Karter appeared as lead counsel in a five week trial for a Fortune 50 company claiming a $423m capital loss from the sale of stock in a contingent liability lease management subsidiary. Herbert Odell is overseeing a multimillion-dollar tax controversy involving proposed adjustments to a large multinational company, and Kevin Johnson has recently obtained the IRS’ complete concession to the most significant issue in a $500m audit involving cross-border financing, thereby reducing the tax in dispute to less than $30m. Jonathan Prokup, also in Philadelphia, and recommended for transfer pricing disputes, is ‘intelligent, thoughtful, analytical, and articulate’. Clients include Sealy Power, Kimberly-Clark, Plains Petroleum and Valero Energy.

Fulbright & Jaworski LLP’s Houston-centered controversy practice is also represented in other Texas cities and New York. Recommended litigators include John Allender, Jasper Taylor and Andrius Kontrimas. Kathryn Keneally in New York has handled numerous IRS investigations for high-net-worth individuals and includes criminal tax proceedings in her practice. Charles Hall, William Lee and Nancy Bowen are members of the team representing Merck in an appeal to the Third Circuit in a suit for the refund of $473m tax and interest; matters in issue include interest rate swaps, the economic substance doctrine, the substance over form doctrine, and the step transaction doctrine. Practice group clients include Triple A Poultry, Baker Hughes, Shell Petroleum and Valero Energy.

Kirkland & Ellis LLP’s tax controversy practice is centered in the firm’s Chicago office, with a secondary presence in Washington DC. The group, which is well-supported by the litigation department, has established a reputation for effective support in administrative appeals and the courts, both in federal and state tax matters. Chicago-based Natalie Hoyer Keller has numerous docketed cases to her credit including the recent representation of Tenet Healthcare. Also in Chicago, Todd Maynes, ‘an excellent tax adviser whose advice is always sound’, includes tax controversy within his practice. Clients include General Motors, Qwest Communications, United Airlines and WR Grace.

Miller & Chevalier Chartered represents more than 20% of the Fortune 500, one quarter of the Global 100 and close to 40% of the Fortune 100 in connection with US federal tax matters. A significant proportion of the Washington DC firm’s work is high-level tax controversy, including complex international transfer pricing matters. With nearly 40 lawyers working wholly or substantially in controversy, the practice has the expertise and capacity to respond to the most challenging instructions. Kevin Kenworthy continues to represent a global petro-chemical giant in connection with high-value disputes. Rocco Femia is recommended for multinational transfer pricing disputes. David Blair has, like many of his partners, served in the government and brings tremendous administrative insight to his controversy work. Alan Horowitz has an impressive appellate practice and frequently appears in the US Supreme Court and federal courts of appeals. George Clarke is recommended for criminal tax defense.

Morrison & Foerster LLP fields ‘high-caliber litigators who play the game to win, but who will not engage in dishonest or unscrupulous tactics’. Craig Fields chairs the firm’s leading SALT controversy. Paul H Frankel, ‘an expert in state tax controversy matters in all states’, has won numerous state supreme court cases for clients including Panhandle Eastern (Kansas), GTE (Kentucky), and Nugget Sparks (Nevada). Frankel and San Francisco-based Andres Vallejo, ‘a very good team’, succeeded in overturning the trial court decision for General Mills before the California Court of Appeal in a high-profile case involving the calculation of the sales factor for apportioning interstate income for a company involved in hedging operations. Also recommended for SALT controversy and litigation are San Francisco-based Thomas H Steele, ‘an outstanding attorney in the state and local taxes area’, and in New York, Hollis Hyans, and Gregory Roberts. The firm’s federal controversy expertise is also noteworthy. Edward Froelich, of counsel in Washington DC and a former trial attorney of the Department of Justice Tax Division, represents clients in all aspects of federal tax controversy and senior counsel James Merritt, also in Washington DC, brings vast experience and gravitas to the group. Practice clients include Sprint Nextel, Reynolds Metal and Science Applications International.

Reed Smith LLP’s nationwide state tax practice is led by Lee Zoeller from Philadelphia, where 15 team members are based. The expanding 18 partner group is also represented in California, and several East Coast states as well as Washington DC. With one of the largest SALT groups in the nation, the firm has the capacity to handle several multistate tax disputes simultaneously and offers excellent client support, from detailed initial business reviews and advice, to expert advice through IRS audits and litigation. Client-acclaimed lawyers include, in San Francisco, John Messenger, who has represented Microsoft in the California Courts. Washington DC-based Donald Griswold, recommended for state tax efficiency reviews of large, multistate businesses, was joined by telecoms state tax specialist Walter Nagel who joined the firm from Sullivan & Worcester LLP in July 2010. Practice clients include Consolidated Freightways, Gannett Corporation, Electronic Data Systems and PTI Communications of Alaska.

Sidley Austin LLP’s tax controversy practice is co-chaired by Laura M Barzilai in New York, and Jay Zimbler in Chicago, and the group is also represented in San Francisco and Washington DC. Zimbler, the firm’s lead tax litigator, has represented Tyson Foods in a series of disputes, the latest being over the availability of research credit for items including the genetic testing of poultry. The firm’s SALT group increased to seven partners in April 2010 when Richard Leavy, previously a partner with Mayer Brown joined the New York office. Other recommended SALT lawyers include Chicago-based Scott Heyman and Tracy Williams, a specialist in the state taxation of insurance companies, who litigated for AIG in several states in cases involving the state taxation of premium and retaliatory taxes. Clifford Gerber in San Francisco is an expert in tax-exempt-financing. Most members of the controversy practice also handle advisory and transactional matters; a combination which clients confirm gives a valuable breadth of approach to IRS audits and administrative appeals. Practice clients include public and private companies, high-net-worth individuals and not-for-profit organizations such as PDV America, PepsiCo, Sprint Corporate and Sears, Roebuck & Co.

Steptoe & Johnson LLP’s tax controversy practice is ‘responsive, and also very proactive in anticipating potential problems and opportunities’ in state and federal tax controversy and criminal tax litigation. Tax policy guru Mark Silverman chairs the group from the Washington DC office, which also houses the majority of the team, with a smaller representation in Phoenix Arizona. Several members of the practice have served in the Justice Department, Treasury or IRS. Recommended litigators in a strong group include the ‘outstanding and extremely professional’ Matthew Lerner, and elder statesman Matthew Zinn for appellate instructions. Philip West and special counsel Michael Durst are ‘excellent in the transfer pricing arena’. The group has particular expertise in insurance sector taxation, in which Arthur Bailey and J Walker Johnson excel: they are currently acting as joint lead counsel for John Hancock Life Insurance in three complex, high-value, tax court cases involving the tax treatment of cross-border leveraged lease investments. Pat Derdenger, in the Phoenix office, has an extensive state and local tax practice. Lawyers named are located in Washington DC unless otherwise indicated. Practice group clients include Fluor Corporation, Koch Industries, Liberty Global, and Procter & Gamble.

Sullivan & Cromwell LLP’s ‘world class responsiveness and client service combine with deep technical knowledge, practical experience and insight’. Washington DC-based head of controversy Donald Korb, former Chief Counsel of the IRS, has ‘unparalleled experience and knowledge in tax controversy work’. The firm’s strategy of targeting UK and French multinationals in need of stalwart representation has been highly successful, current instructions include the representation of a European company in an IRS examination involving a debt/equity issue with over $2bn in potential tax liability, and advising another European company in an IRS examination involving a worthless stock deduction with over $10bn at stake. Diana Wollman in the New York office is also recommended.

Sutherland Asbill & Brennan LLP has a 25-strong SALT group with ‘a very deep bench – probably the best state and local tax practice in the United States’. The expanding practice is chaired by Washington DC-based Jerome Libin, who has a ‘breadth of knowledge combined with his experience in tax litigation which permits him to provide advice from both a technical and practical viewpoint’. Atlanta’s Eric Tresh and Washington DC’s Jeffrey Friedman are ‘both top notch advisers and advocates who strike a prudent balance between aggressiveness and pragmatism’. The firm also continues to attract prestigious federal tax instructions; Kent Jones and Daniel Schlueter are leading the representation of Procter & Gamble in a $434m refund suit involving several issues, including a novel challenge to the IRS’ treatment of intercompany gross receipts in determining the amount of the research tax credit. In Atlanta, Jerold Cohen and Matthew Gries are recommended. Practice clients include General Electric and State Farm Mutual Auto Insurance.

Baker Botts L.L.P. has ‘knowledge and experience in the particular field of estate tax disputes’, particularly those involving difficult valuations such as interests in closely held businesses, family limited partnerships and limited liability companies. John Porter, ‘the best in this field in the country’, and Keri Brown succeeded for the taxpayer in the extraordinarily complex Estates of Black v Commissioner of Internal Revenue, a case which involved trusts, a limited partnership and valuation issues. In a federal tax matter, in which the practice is ‘very knowledgeable about IRS practice and procedure’, Richard Husseini’s team successfully settled a dispute with the IRS relating to an interest allocation study utilizing the fair market value method of valuing assets in the hundreds of billions of dollars. The firm’s clients include Southwest Airlines, United Parcel Service of America, Pennzoil Company and Mariner Energy.

Greenberg Traurig LLP’s tax audits & litigation practice is chaired by the ‘highly skilled and persuasive’ Barbara Kaplan from the New York office. The group includes some highly experienced, ex-IRS litigators who are particularly experienced in pursuing tax refund claims in federal district court. The experienced Thomas Sykes joined the Chicago office from McDermott Will & Emery LLP in May 2010. Recommended attorneys include New York’s David Bunning, who has ‘a very clear mind and is able to present complex tax matters in a simple and understandable manner’; and Phillip Pillar, who works from Washington DC and Philadelphia, ‘very good with tax controversy and has a very strong overall tax technical knowledge’ and recently represented a major insurance company group in IRS appeals regarding a multi-issue, multimillion-dollar refund claim.

Morgan Lewis’ tax controversy group is led by the ‘amazingly effective, a true leader in the discipline’ Miriam Fisher, who is Washington DC-based along with the majority of her 20-strong team. The group provides both federal and SALT support in controversies, and with mixed-practice partners, is strong in administrative appeals work. Gary Wilcox in Washington is a former Deputy Chief Counsel for the IRS. William Colgin in San Francisco is an experienced trial attorney. SALT expert Kimberley Reeder joined the Palo Alto office in March 2010.

Winston & Strawn LLP signalled a strengthening of the federal tax controversy offering in October 2010 when specialist Daniel Dumezich was recruited to head the practice from Mayer Brown, along with long-term colleague Gary Colton. The recruitment suggests a shift in strategy for the firm whose tax partners have generally combined advisory and controversy practices, working with litigation partners where necessary – the highly accomplished James Lynch and Louis Weber have acted for Yum! Brands, the owner of Pizza Hut and KFC, in various tax controversy matters over the years, including one involving the formation and stock sale of a captive insurance subsidiary. Charles Moll leads the firm’s nationwide state and local tax practice from the San Francisco office; other partners named are based in Chicago. Clients assisted in controversy matters include Elan Pharmaceuticals, Sara Lee and AT&T.

Alston & Bird LLP’s eight-partner tax controversy group, ‘true tax litigators’, is headed by Michelle Henkel in Atlanta where the majority of group is based; two partners practice from the Washington DC office. Although modest in size, the firm has achieved a national reputation representing taxpayers in domestic and international tax disputes including audits, administrative appeals, trials and mediation. Highly respected for financial sector and partnership cases, the lightly leveraged team has an excellent reputation for client support. Michael Petrik chairs the firm’s SALT excellent group which regularly handles multimillion-dollar disputes for leading corporates. Clients include Delta Air Lines, AT&T, Coastal Utilities, Wellpoint and Exxon Mobil.

Cooley LLP’s tax controversy partners are recommended for administrative tax controversies and tax litigation at both state and federal level. New York-based Stephen Gardner, ‘an outstanding professional and one of the best tax litigators in the country’, and William O’Brien led the work for Entergy Corporation in the US Tax Court, and succeeded in confirming the company’s entitlement to a $250m foreign tax credit for taxes paid by its subsidiary in the UK. Kathleen Pakenham joined the New York office from White & Case LLP in the summer of 2010, bringing the controversy partner count to five. David Fischer in the Washington DC office is highly rated by clients. Clients include American Express, Coltec Industries, ConocoPhillips, Goodrich Corporation, Shell and Walter Industries.

Pillsbury Winthrop Shaw Pittman LLP’s Washington DC-based Eileen O’Connor, a former Tax Division assistant attorney general, leads the firm’s federal tax controversy team, and ‘cerebral, polished, extremely knowledgeable’ Jeffrey Vesely heads the firm’s SALT controversy group from San Francisco. Both groups are ‘exceedingly responsive and creative, and always bring their best team to the table’. Highly rated lawyers specializing in federal tax include William Bonano in San Francisco, whose practice includes transfer pricing and whose ‘litigation and appeals experience make him the ideal advisor’. In recent SALT litigation, Annie Huang and Jeffrey Vesely successfully represented HSBC subsidiary Beneficial New Jersey in a lead case challenging New Jersey’s recently enacted interest add back law. Practice clients include Cardinal Health, Chevron, Cisco Systems and Xerox.

Vinson & Elkins L.L.P. tax controversy group ‘always has its client’s needs in mind – the attorneys go out of their way to meet deadlines’. Department head George Gerachis from Houston, who ‘provides the highest quality of service with the appropriate level of advice’, has represented Halliburton in federal income tax disputes involving a variety of domestic and international issues, including research and development tax credits relating to Halliburton’s oilfield services technology. The team includes Donald Wood in Austin, who includes complex estate tax matters within his expert practice, and a very promising associate in Houston, Tobey Forney, who is ‘professional, personable, practical and very good at research and establishing positions’. Clients include Hines Interests, Transocean and Thomas Properties Group.

White & Case LLP’s controversy practice is based round a core group of attorneys in Washington DC and New York, headed by Michael Quigley, who has wide experience of administrative appeals and tax litigation. Brian Gleicher specializes in transfer pricing disputes. The practice has considerable expertise in the insurance sector, and recently successfully represented a client before an Ohio District Court in a case of first impression concerning the interplay between the IRS and guidance issued by the National Association of Insurance Commissioners relating to the computation of insurance tax reserves. Clients include Clear Channel Communications, American Financial Group, AOL Time Warner and Citigroup.