The Legal 500

Twitter Logo Youtube Circle Icon LinkedIn Icon

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

Joel Williamson

Tel:
Work +1 312 701 7229
Email:
Mayer Brown

Work Department

Tax Controversy

Position

Joel Williamson is widely acknowledged as one of the nation’s leading tax attorneys and litigators. He has litigated over 60 tax cases. His experience includes the trial of six major IRC § 482 transfer pricing cases, including Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, and United Parcel Service. Presently, Joel is serving as lead trial counsel in Guidant LLC and Eaton, two cases involving IRC § 482 issues. Joel has also litigated numerous cases involving economic substance of transactions, including the United Parcel Service case noted above, as well as the Saba Partnership (Brunswick) case, and Mukerji (Comdisco), an important test case for tax-advantaged computer leasing transactions involving Comdisco. More recently, Joel Litigated ConEd which involved an international Lease-In-Lease-Out transaction and Flextronics which involved an international merger and acquisition transaction. Both ConEd and Flextronics witnessed IRS arguments of economic substance and generic tax doctrines including substance over form and step transaction. In the international tax area, Joel has litigated Subpart F, constructive triangular dividend, R&D Moratorium, Brazilian and other foreign tax credit for banks, including Bankers Trust and Riggs Bank, as well as Iranian loss investment in U.S. property (IRC § 956) and foreign-versus-domestic-source income (IRC § 863(b)) questions. He has litigated two significant captive insurance cases involving Humana, Inc. and Gulf Oil Corporation. In addition, Joel has litigated IRC § 338 corporate acquisition related issues, including goodwill, intangible and inventory valuations and second-tier allocations involving Nestlé’s acquisition of Carnation. Joel litigated the Tribune Company case, which dealt with whether a divestiture of a subsidiary qualified as a tax-free corporate reorganization. He has litigated significant tax accounting issues, including unbilled revenue and cap interest rate loan questions. Joel has also litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process. He is also experienced in summons enforcement actions for both foreign and domestic records. Chambers, a leading professional directory, consistently recognizes Joel as an industry leader. Chambers USA 2010 called Joel “a dean of the tax controversy Bar, revered for his ‘spectacular courtroom manner and skills.’” In 2009, Chambers USA noted his “unparalleled battleground experience.” According to Chambers USA 2008, Williamson utilizes his “great courtroom presence” to remain “constantly on top of his game.” He attracts compliments for his skilful handling of executive clients, strategic insights and “exhaustive preparation.” Sources conclude that this “fearless and tireless” attorney never fails to imbue clients with complete confidence. In 2007, Chambers USA observed that "Joel is one of the most successful controversy attorneys in the USA . . . his experience is almost unrivaled . . . [he is an] 'obvious standout' in the national tax market . . . [and is] 'especially adept at arguing the most technical issues.'" Chambers USA 2006 wrote that he was "much admired in the profession for his ability to identify the issues at hand quickly and incisively." Chambers Global 2006 wrote that he "'probably has more experience in litigating cases than any lawyer in the USA'...'enormous presence and stature' [with] 'long history with transfer pricing litigation.'" Joel is proud to have been recognized by Chambers USA as: "Leading Lawyers," 2003-2004, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011 and 2012 and by Chambers Global as: "Leading Lawyers, Tax - Chicago," 2001-2002; "Leading Lawyers, Tax - Illinois," 2003; "Leading Lawyers, Tax - National," 2006; "Leading Lawyers," 2003-2004, 2004, 2005, 2006, and 2007. In addition, he is recognized by Legal 500 as a "Leading Lawyer" in 2008 and 2011. He is further recognized as a leading Tax Controversy adviser in the 2012 International Tax Review “Tax Controversy Leaders Guide.” Joel served as an officer in the United States Army from 1970 through 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the Chief Counsel’s Office, US Department of Treasury. In 1978, he was appointed one of 20 Special Trial Attorneys located throughout the United States. Joel joined Mayer Brown in 1986 and was named partner that same year.

Education

Davidson College, BA University of Kentucky College of Law, JD University of Kentucky Law Review; Moot Court Board; National Moot Court Team Order of the Coif


United States: Tax

US taxes: contentious

Within: Leading lawyers

Joel Williamson - 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.

[back to top]


Back to index

Legal Developments worldwide

Legal Developments and updates from the leading lawyers in each jurisdiction. To contribute, send an email request to