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Mayer Brown

71 SOUTH WACKER DRIVE, CHICAGO, IL 60606, USA
Tel:
Work +1 312 782 0600
Fax:
Fax +1 312 701 7711
Email:
Web:
www.mayerbrown.com

Thomas Kittle-Kamp

Tel:
Work +1 312 701 7028
Email:
Mayer Brown

Work Department

Tax Controversy

Position

Since joining Mayer Brown in 1990, Tom Kittle-Kamp has represented clients in all phases of tax controversy and litigation. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterization, valuation disputes, capitalization questions, Subpart F and other international tax issues, Subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS Appeals (including Fast Track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes. Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licenses, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter.

Education

Northwestern University School of Law, JD, cum laude, 1988; Associate Editor, Law Review, Order of the Coif Bradley University, BA, summa cum laude, 1982


United States: Tax

US taxes: contentious

Within: Leading lawyers

Thomas Kittle-Kamp - Mayer Brown

Within: US taxes: contentious

The ‘incredibly knowledgeable’ team at Mayer Brown includes Chicago-based Thomas Kittle-Kamp, who has been advising Altera on an IRS appeal seeking to overturn the Tax Court’s decision agreeing with the client that the IRS equity compensation regulation is invalid due to procedural and substantive faults under the Administrative Procedure Act. Joel Williamson and John Hildy (both located in Chicago) have been acting for Hyatt Hotels in a Tax Court case concerning the treatment of Hyatt’s customer loyalty program. New York-based Brian Kittle, a ‘clear star’, has been assisting Canada Imperial Bank of Commerce (CIBC) with a matter involving the deductibility of certain settlement expenses and the allocation of such expenses among CIBC’s various entities in Canada and the US. Palo Alto’s Larry Langdon and Washington DC’s Gary Wilcox are other notable names.

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